Pillar Client Services filed its response to FCA CP26/10 on 12 May 2026. The consultation deadline is 22 May. We filed early because the substance of the response was settled, our operational data is live, and there is no advantage in waiting.
Why we filed early
CP26/10 has been the dominant regulatory conversation for IFA firms since publication on 25 March. Most responses will land in the final week. By filing on 12 May we put our position in front of the consultation team while there is still time for it to inform the FCA's thinking, rather than after the queue closes.
There is a second reason. We are talking to firms every week about what CP26/10 means for their sub-threshold books. Having a filed response under our name puts something concrete on the table when those conversations happen. Firms can read it, push back on it, borrow from it, or ignore it. The point is that it exists.
The three arguments
Frequency cadence is the right direction. The proposed move from a blanket annual review obligation to a segment-justified periodic cadence is sensible. What the consultation paper does not say loudly enough is that the burden on the firm goes up, not down. Justifying a longer cadence per segment is harder than running an annual review by default. The response argues for explicit guidance that defaults toward more frequent review where the firm cannot evidence segment stability.
The evidence burden binds either way. A firm charging ongoing fees has to demonstrate ongoing service. That obligation does not lift if review frequency falls. If anything it tightens, because the periods between reviews now have to be evidenced through monitoring rather than through the review itself. Firms reading CP26/10 as permission to do less are reading it wrong.
The CBA understates the outsourcing case. The cost-benefit analysis in the consultation paper assumes review delivery sits with the adviser. That is the expensive way to do it. Structured periodic review delivered by trained staff, operating inside the firm's own systems, costs a fraction of adviser time. At the launch client, a 5% escalation rate has turned the long-tail book from a cost centre into a revenue channel, with escalations becoming new advice opportunities that carry both initial and ongoing fees. The CBA does not capture that revenue dynamic.
The 16 April distribution chain point
The FCA published observations on distribution chain responsibilities on 16 April 2026. We treat those as the second binding constraint inside CP26/10, not a separate workstream. Manufacturers, platforms and advisers cannot evidence Consumer Duty outcomes for sub-threshold cohorts without outcomes data at the client level. The simplest way to capture that data is a structured periodic review. The point we make in the response is that distribution chain compliance and CP26/10 review compliance are the same problem viewed from two angles.
The audit trail as by-product
Every structured review we run produces a documented file note, vulnerability screening, Consumer Duty outcomes, escalation decision, and MI line item. That output is the audit trail the FCA expects, generated as a by-product of the review activity itself. No separate compliance project. No retrofit exercise. The work of the review is the work of the evidence.
This is the operational point the response leans on hardest. Firms that build their review programme around evidence capture from the first review will not face a separate compliance build later. Firms that defer the question will end up building the audit trail twice.
What is in the response
Seven questions answered (Q7, Q8, Q9, Q10, Q15, Q16, Q22). Two exhibits. Exhibit A maps structured periodic review evidence to the four Consumer Duty outcomes. Exhibit B sets out our live operational data: 200 client reviews, a 5% escalation rate, a 90% quality-audit pass rate, and £55,000 of new revenue generated.
The full response is downloadable as a PDF, around 130 KB.