Blog
Practical thinking on outsourced reviews, regulatory change, and IFA operations.
Pillar has filed its response to the FCA ten days ahead of the 22 May deadline. The full response is downloadable here. We connect the consultation to the 16 April 2026 distribution chain observations and ask the FCA to recognise outsourced non-advice review under principal-firm governance.
Read more →Most IFA firms think CP26/10 means fewer annual reviews. It doesn't. It means proving ongoing value becomes harder, not easier. If you can't document that, you lose the right to charge.
Read more →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.
Read more →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.
Read more →We ran a structured pilot with a live IFA firm: 10 client reviews, full compliance documentation, vulnerability screening. The result was a 20% escalation rate, identified Year 1 revenue, and a 2.4x return on cost.
Read more →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.
Read more →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.
Read more →CP26/10 updates, Consumer Duty guidance, and practical advice for IFA firms. No spam.