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Articles and analysis

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

A fair value assessment built on firm averages will not survive the FCA's test

What the FCA's price and value findings mean for an adviser firm's ongoing fee, why firm averages hide poor value, and what a client-level assessment looks like.

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Your Consumer Duty board report needs client-level evidence, not a summary

The FCA read 180 firms' first Consumer Duty board reports. Its main complaint was conclusions the data could not support. What the evidence in an adviser firm's report should look like.

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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, live Consumer Duty enforcement, 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 and early operating data from our launch client.

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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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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, and around 190 clients handed back without escalation (as recorded by the launch client, April 2026).

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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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