Our response addresses CP26/10 from the position of an outsourced client review operator working inside live IFA firms with sub-threshold books. The submission is grounded in operational data from the live deployment at the launch client: 200 client reviews, a 5% escalation rate, a 90% quality-audit pass rate, and £55,000 of new revenue generated.
The response makes three core arguments. First, the proposed periodic review cadence is the right direction of travel, but the framing should make explicit that frequency must be justified per client segment rather than reduced by default. Second, the evidence burden binds firms whether they review or not, because the obligation to demonstrate ongoing service continues for as long as ongoing fees are charged. Third, the cost-benefit analysis in the consultation paper understates the case for outsourced review delivery and overstates the cost of structured periodic review at firms with substantial long-tail books.
The submission also addresses the FCA's 16 April 2026 statement on distribution chain responsibilities. We argue these observations are 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 a structured periodic review programme that captures outcomes data at the client level.