Ask most advice firms how they assure quality, and you’ll get a familiar answer: “We do QA checks after the file’s been submitted.” But here’s the rub. If your quality control only kicks in at the end, you’re not protecting your clients. You’re just crossing your fingers.
At We Complement, we believe the future of advice assurance isn’t reactive. It’s structured, evidentiary, and embedded from the start. And that’s where the Suitability Consultant comes in.
Why Traditional QA Isn’t Enough
Let’s be clear. Retrospective file checks still have a place. But they can’t carry the weight of regulatory expectation on their own. They’re too slow to prevent harm, too subjective to be consistent, and too backward-looking to drive change.
Retrospective QA creates what we call a “file repair culture.” Mistakes get patched, but root causes go unaddressed. That’s risky, especially under Consumer Duty, where firms must show how their advice actively delivers good outcomes, not just avoids harm after the fact.
Key rules like:
- COBS 9.2.1R (client suitability)
- SYSC 3.2.6R (risk systems and controls)
- PS22/9 (Consumer Duty)
…all require more than a tidy report. They demand a traceable advice logic that can stand up to internal scrutiny, external audit, and the FCA’s expectations for evidentiary discipline.
The Shift: Advice Built to Be Audited
Suitability Consultants operate differently.
Where a traditional paraplanner might build a report around adviser input, we start earlier in the process — testing the inputs themselves. Is the risk profile consistent with the objectives? Do the factfinding notes back up the recommendation? Are product choices driven by need, not preference?
Our process uses a structured toolkit:
- ARC (Advice Readiness Checks): Pre-advice triage that surfaces gaps in client context, factfinding, and risk profiling.
- ASL (Advice Suitability Logic): A 130+ rule framework to test alignment to FCA standards.
- SMS (Suitability Matrix Score): A logic-graded, versioned evidence report that supports both internal QA and external defence.
From QA to Proactive Precision
This isn’t about more process. It’s about smarter structure. When advice is built using embedded frameworks, QA becomes a formality. By the time the file lands in compliance’s hands, the logic is already documented, tested, and version-controlled.
Think of it this way:
- Traditional QA: “Does this advice meet the standard?”
- Suitability Consultant: “Let’s make sure the advice was built to the standard.”
That’s a big difference. It moves assurance upstream, where it can actually influence outcomes.
What This Means for Your Firm
If you’re still relying solely on end-stage checks, you may be exposing your firm to:
- Governance gaps — where override patterns go unnoticed
- Rework and delays — from back-and-forth file edits
- Audit risk — because logic can’t be clearly evidenced
- Inconsistent advice — when paraplanners have to “make it fit” post-fact
By embedding a Suitability Consultant model, you get:
✅ Advice logic aligned before submission
✅ FCA-mapped standards from start to finish
✅ Evidentiary assurance that supports SM&CR accountability
✅ Fewer escalations, faster delivery, and stronger client outcomes
Practical Tip: Test Your Own Files
Want a quick way to see if your process is fit for purpose? Pick three recent advice cases and ask:
- Could someone with no context follow the logic from factfind to recommendation?
- Are product choices justified in the client’s words, not just the firm’s preferences?
- Would the file survive scrutiny without any “explainer” from the adviser?
If you answered “no” to any of those, don’t worry. It just means there’s room to evolve.
A New Standard Is Emerging
As regulation tightens and insurers demand more rigour, firms can’t afford to view QA as a final checkbox. The bar is rising. The ability to show how advice was constructed — step by step, standard by standard — is becoming a baseline expectation.
Suitability Consultants aren’t just helpful. They’re strategic infrastructure. And for firms who want to stay ahead, they may be the most valuable hire you’ve never made.
