Ian

This month has been a particularly active one for the FCA. Individually, none of the updates feel dramatic, but together they point clearly towards the direction of travel for 2025. As always, the FCA is focused on consistency, clarity, and consumer protection. For advisers and paraplanners, this is another reminder that evidence and governance matter just as much as the recommendation itself.

Below, I have summarised the key updates along with some practical reflections to help you keep your advice files strong and review ready.

**1. Consolidation in Advice and Wealth Management

Why the FCA is paying closer attention to scaling firms**

The FCA has released its review on consolidation in the advice and wealth management sector: https://www.fca.org.uk/news/news-stories/review-consolidation-financial-advice-and-wealth-management-sector

The trend is clear. More firms are being acquired, merged, or absorbed into larger groups. What concerns the FCA is whether those firms can maintain advice quality and control as they grow. Consumer Duty has made it obvious that process variability is no longer acceptable.

From an advice perspective, the biggest challenge sits in consistency. Different advisers across acquired firms often work with different templates, rationales, and approval checkpoints. That becomes a governance risk the moment firms start scaling.

My advice to teams is simple. Tighten your frameworks before the FCA tightens theirs. Review your templates, revisit your rationales, and ensure your records clearly evidence client objectives and suitability logic. Growth is positive, but only if the advice process grows with it.

**2. Crypto Exchange Traded Notes

A timely reminder on client categorisation**

The FCA has issued a fresh reminder around the rules for crypto ETNs, with a clear warning about inappropriate promotion: https://www.fca.org.uk/news/statements/information-firms-offer-crypto-exchange-traded-notes

Crypto ETNs remain high risk. The FCA has restated that firms must be strict in how they assess and evidence client categorisation.

For advisers and paraplanners, this is a good moment to revisit your segmentation notes. Many clients appear financially savvy but do not meet the bar for elective professional status. Suitability reports should clearly record the fact that these products were considered out of scope and why.

If your advisers receive crypto related questions, make sure they know the criteria for professional classification and where the lines are. Clear documentation protects both the client and the firm.

**3. Romance Scams

A reminder of why vulnerability evidence matters**

The FCA is urging banks to do more to prevent romance scams: https://www.fca.org.uk/news/press-releases/banks-need-to-help-break-spell-romance-scams

While this is a retail banking issue, it connects strongly to advice. Vulnerability can be subtle and situational. Clients who appear confident and independent on paper can still be at risk of manipulation.

From an advice quality perspective, this is a reminder to:

• Build vulnerability observations into annual reviews.  • Record behavioural changes in CRM notes.  • Make clients aware of your firm’s security protocols, especially around transfers.

Good vulnerability evidence is not about ticking boxes. It is about protecting clients in moments when they might not recognise a risk themselves.

**4. FCA Charges Three Finfluencers

What this means for advice firms who create content**

Three finfluencers have appeared in court after an FCA led crackdown on illegal promotions: https://www.fca.org.uk/news/press-releases/first-court-appearance-three-finfluencers-charged-fca-led-global-crackdown-illegal-promotions

Although most advice firms are not making TikTok content, this update is still relevant. It shows that the FCA is widening the scope of what counts as influence, and it expects anyone shaping financial decision making to follow financial promotion rules.

If your firm uses social media, webinars, newsletters, or YouTube, now is a good time to double check your content. Balance, risk warnings, and clarity on what is and is not advice need to be watertight.

For paraplanners who support content creation, remember that generic guidance must stay well away from personalised implications. A single loose phrase can change the nature of a post.

**5. FCA Opens Applications for Three Statutory Panels

A signal of more industry dialogue ahead**

The FCA is opening applications for three of its statutory panels: https://www.fca.org.uk/news/news-stories/fca-opens-applications-3-key-statutory-panels

This is a healthy development. It suggests the FCA wants a closer link with real adviser experience and technical insights from the industry.

If your firm has strong views on Consumer Duty, PI volatility, redress, or governance challenges, this is the moment to contribute via associations or directly through panel applications. The more practitioners involved, the more grounded the regulatory conversation becomes.

Final Thoughts

When you look at all of these updates together, the theme is easy to spot. The FCA wants stronger evidence, clearer logic, and better governance discipline across advice firms of all sizes. That aligns with what we see daily. Good advice is not just well written, it is well evidenced, well documented, and resilient under review.

If any of this reflects conversations you are having in your firm, we would be happy to talk it through.

You can’t open Professional Paraplanner this month without seeing the same headline: billions of pounds still sitting in savings accounts earning 1% or less.

It’s easy to understand why. After a decade of shocks – inflation, interest-rate jumps, and market whiplash – investors have grown cautious. But as we move towards 2026, that caution is quietly becoming costly.

The illusion of safety

Holding cash can feel like control. It’s visible, accessible, and seemingly “risk-free.” But when inflation averages 4%, £100,000 in a 1% savings account loses more than £9,000 of real value in three years. The line between prudence and erosion is thinner than most realise.

As advisers know, inaction is still a decision – one that can materially shape long-term outcomes.

Re-framing risk for clients

The challenge isn’t convincing clients to be brave; it’s helping them see that:

• Risk managed is not risk ignored. Diversification, time horizons, and product design all have structure and discipline behind them.
• Cash can be purposeful. Emergency funds are essential, but anything beyond that should serve a defined objective.
• Inflation is the silent loss. Use simple illustrations to make real-term erosion visible – it often changes the conversation faster than a market forecast ever could.
• Suitability is the anchor. Every portfolio decision should still be evidenced against the client’s objectives and appetite for loss.

Platforms and products expanding access

The industry is also adapting. HSBC’s Model Portfolio Service (MPS) is now live on Parmenion, Nucleus, and Novia, adding to an already broad list of platforms – from Aviva and Abrdn Wrap to Transact and 7IM. Greater accessibility means it’s becoming easier for advisers to offer risk-appropriate, diversified solutions without operational friction.

Similarly, Elston’s Smoothed MPS via Aviva highlights the shift toward products that keep clients invested while reducing volatility – a useful middle ground between fear and opportunity.

Why this matters now

When markets wobble, “safe” often feels like the right call. But from a suitability perspective, the adviser’s role is to bring balance – to turn emotional caution into structured confidence.

That’s where disciplined advice makes its mark: evidence-based recommendations, defensible rationale, and clear communication that bridges logic and reassurance.

Because safety, when left untested, isn’t really safety at all. It’s just deferred risk in another form.

If this reflects what you’re seeing in your client conversations, I’d love to hear how your firm is approaching it. No pitch – just a shared discussion on how we can keep advice grounded, balanced, and built to last.

The appeal never gets old

Few assets spark the same emotion as a classic car. For some, it’s the growl of a V12; for others, it’s the nostalgia of a Sunday drive with the roof down. But beyond the romance, classic cars are increasingly being discussed as serious investments – part collectible, part alternative asset class.

With demand for rare models and limited supply, the numbers have been impressive. According to Classic Car Clubs UK’s Q1 2025 Market Report, blue-chip classics like the Jaguar E-Type and Porsche 911 Turbo continue to hold value even in volatile markets. Yet, as advisers and paraplanners know, emotional assets can be tricky to quantify – and even trickier to justify in a diversified portfolio.

So, are collectible cars a legitimate long-term play, or just a beautifully polished gamble?

Understanding what drives the market

The Wealthspireanalysis ¹ breaks the investment case into three forces: scarcity, sentiment, and stewardship.

• Scarcity– production numbers are finite, and many vehicles are already lost to time.

• Sentiment– cultural cachet drives demand (think Bond-era Aston Martins or 80s Ferraris).

• Stewardship– the condition and provenance of the car determine its resale trajectory.

That last point is critical: these assets need constant care. A car that isn’t driven or maintained can depreciate faster than a bear-market portfolio.

The risk under the bonnet

The Credence Research ² and Goodsong Gallery ³ pieces agree; while headline returns can hit double digits, costs and liquidity risks are substantial.

• Maintenance & storage: Insurance, servicing, and climate-controlled storage can exceed 2–3% of value per year.

• Liquidity: Cars aren’t traded on an exchange – selling takes time, connections, and sometimes luck.

• Valuation volatility: Prices are often driven by auction trends, not fundamentals.

• Regulatory risk: Environmental legislation may tighten restrictions on older vehicles, impacting use and resale.

In other words, classic cars behave more like art than equities.

Portfolio fit: diversification or distraction?

According to Sierks Investors Magazine ⁴, the global collectible-car market is maturing. Institutions are beginning to index data on vintage-car performance, making it easier to model correlations with traditional assets. Early findings suggest low correlation with equities and bonds, which could make a small allocation (typically < 5%) a genuine diversifier – for the right client.

However, it’s not suitable for everyone. Advisers need to consider:

• Client objectives– is this wealth preservation, legacy planning, or lifestyle investing?

• Liquidity needs– will the client need to access capital quickly?

• Knowledge and engagement– does the client understand the market, or are they relying on third-party dealers?

As Luhhu Finance⁵ notes, successful collectors often treat their garages like businesses: meticulous records, regular valuations, and a clear sell strategy.

The UK scene in 2025

Market data from ClassicCarClubs.uk’s Q1 2025 analysis shows UK transactions slightly down in volume but up in average value – suggesting consolidation among serious collectors. Electric-vehicle policies have also boosted interest in “final-generation” petrol icons like the BMW M3 E92 and Audi R8 V10, listed by Auto Express ⁷ as among the “future classics”expected to appreciate over the next decade.

For high-net-worth clients, this isn’t just nostalgia – it’s a potential hedge against monetary inflation and currency fluctuation, albeit one best viewed through a long-term, discretionary-portfolio lens.

Practical takeaways for advisers

If a client raises classic cars in an investment meeting, consider framing the discussion around:

1. Purpose before product– clarify whether this is an emotional purchase or a portfolio allocation.

1. Full-cost view– include storage, insurance, and restoration in any ROI discussion.

1. Exit planning– how and when will value be realised, and through which channels?

1. Due diligence– verify provenance and authenticity; partner only with reputable auction houses or dealer networks.

1. Tax and reporting– remember that cars may not qualify for capital-gains exemptions and can complicate estate planning.

The bottom line

Classic cars can bring joy, status, and – in the right hands – returns. But they’re illiquid, maintenance-heavy, and sentiment-driven. As advisers, our role is to help clients balance passion with prudence, ensuring the thrill of ownership doesn’t override the discipline of investment.

If this resonates with what you’re seeing among your clients, we’d love to hear your perspective. Have you encountered more “alternative asset” conversations recently?

¹ Wealthspire: Investing in Collectible Cars (2025)

² Credence Research: Classic Cars as Investments (2024)

³ Goodsong Gallery: Are Classic Cars Still a Good Investment?

⁴ Sierks Magazine: Classic Cars as an Investment – Guide for Investors (2025)

⁵ Luhhu Blog: Why Investing in Vintage Cars Makes Financial Sense

⁷ Auto Express: Best Future Classics 2025

Retirement advice is having a moment. Between rising client expectations, looming tax changes, and the FCA’s sharper focus on Consumer Duty outcomes, suitability in retirement planning has never felt more scrutinised – or more complex.

Recent research from FT Adviser found that suitability reports remain a “constant choke” for advisers. The same message echoed across Professional Paraplanner’s autumn surveys: advisers are spending more time on report drafting than on client conversations, with pressure peaking around pension and decumulation cases.

The problem isn’t that advisers don’t know what to say.  It’s that the how– how to evidence rationale, balance flexibility and sustainability, and present recommendations in plain English – still feels too heavy for most workflows.

1. The Pension Pressure Cooker

Fidelity Adviser Solutions’ latest adviser research showed a marked rise in retirement income reviews this quarter, as clients seek to “get ahead” of potential Budget changes. That’s pushed paraplanning and suitability teams into overdrive – especially around drawdown sustainability and sequencing risk analysis.

Clients are understandably cautious. Many have seen markets recover since 2022 but remain wary of volatility and tax drag. Advisers, meanwhile, are wrestling with how to present complex pension logic clearly, without burying clients in detail or triggering rework at QA.

The bottleneck isn’t just technical. It’s structural. Most retirement advice still relies on sequential handovers between adviser, paraplanner, and reviewer – a process that was designed for regulatory safety but now hinders it. Every pass adds delay and dilutes accountability.

At We Complement, our suitability consultants are seeing that the fastest, cleanest outcomes come when logic is evidenced as it’s built. That means integrating fact-finding, objective validation, and product alignment before the report even hits a QA queue.

2. From Paraplanning to Proof

The industry’s language is shifting. “Suitability Consultant” isn’t just a new title – it’s a reflection of the role’s evolution.  Where a paraplanner traditionally constructed reports based on adviser input, a suitability consultant now tests and evidences the advice itself.

That proactive discipline changes everything:

• Errors are caught early, not patched later.

• Logic is consistent across advisers and files.

• QA becomes confirmation, not reconstruction.

As the FCA continues to assess Consumer Duty implementation, firms that can show advice integrity at the point of creation – not just in hindsight – are finding themselves on stronger ground.

It’s the difference between checking quality and proving suitability.

3. A Shift in Adviser Behaviour

The same Professional Paraplanner data found that over half of advisers are now “actively revisiting” retirement frameworks in anticipation of policy or tax change. But there’s a second driver: advisers want reassurance that their advice process is robust enough to withstand audit, even when circumstances shift.

In our own consulting work, we’re seeing three practical changes that make a difference:

1. Clearer objectives mapping. Linking every recommendation to a measurable client goal, not a generic outcome.
2. Version-controlled reasoning. Keeping an auditable record of every change – who made it, and why.
3. Embedded suitability scoring. Using structured frameworks (like our Suitability Matrix Score) to turn subjective “good” into objective evidence.

These are not just compliance niceties; they’re governance tools that de-risk advice teams and build confidence with both clients and regulators.

4. The Retirement Advice Balancing Act

Retirement advice has always been the ultimate test of judgement – balancing today’s client emotions with tomorrow’s unknowns.  But under Consumer Duty, that judgement must now be demonstrably reasonable. The regulator isn’t just asking whether a client’s plan makes sense; it’s asking whether the processthat produced it is reliable, repeatable, and aligned to FCA rules.

That means suitability isn’t a one-off test; it’s a continuous discipline.

• COBS 9.2.1R requires firms to ensure suitability of recommendations.

• SYSC 3.2.6R demands that systems themselves prevent foreseeable harm.

• Consumer Duty Outcome 1 obliges firms to prove good client outcomes, not just intend them.

In practice, those three lines converge in a simple principle: advice should stand up the first time.

5. Looking Ahead

With the Autumn Budget approaching and client nerves heightened, advisers face another surge in last-minute pension reviews. The firms that thrive through it will be the ones that treat suitability as a live process, not an end-stage hurdle.

We Complement’s view is that the answer lies in Advice Integrity – embedding evidence and alignment from the first client conversation through to final file.  When suitability becomes part of the advice build, retirement planning stops being a choke point and starts being a confidence point.

Final Thought

Retirement advice will always be complex. But complexity doesn’t have to mean opacity.  The firms that simplify the path – for advisers, for clients, and for auditors – are the ones that will win both trust and time.

If this resonates with what you’re seeing in your own firm, we’d love to hear from you.  No pitch. Just a conversation between people who care about getting advice right.

Why “intelligible pensions” is the tech question of our time

Ask any adviser or paraplanner what’s hardest to explain, and pensions will be near the top of the list. Between legacy schemes, tax quirks, retirement choices and regulation, even a “plain English” summary can sound like a puzzle.

So when I saw the headline “Could AI be the answer to making pensions intelligible for all?”– I stopped scrolling. Because if there’s one part of advice crying out for clarity, it’s pensions.

This month’s TechTalk takes that question and pairs it with three big tech moves in our sector – to explore how AI might finally help advice make senseto everyone.

1 | “Intelligible” isn’t simple – it’s structural

A recent Professional Adviser article hit the nail on the head: pension language isn’t confusing by accident. It’s confusing because the system itself is complex. AI can’t magic that away – but it canact as a translator between the system and the saver.

In practice, that could mean:

• Explaining scheme rules or benefits in plain, personal terms

• Letting users ask questions in their own words (and get answers that build confidence)

• Tailoring explanations to different literacy or knowledge levels

• Spotting when someone’s lost, and suggesting when to bring a human into the loop

We’re already seeing early versions of this – “pension specialist” chatbots that can interpret scheme documents and respond conversationally. It’s promising, but as always, the line between simplification and distortion is thin. Accuracy, oversight, and context are everything.

2 | AI is moving from experiment to infrastructure

If you look at what’s happening across financial services, the pattern is clear – AI isn’t just a novelty anymore. It’s being built into the backbone of how firms work.

• Legal & General × Microsoft are using AI to enhance client interactions and anticipate needs.

• AJ Bell + Dynamic Planner have integrated to remove manual handoffs – the groundwork AI depends on.

• Nucleus / Third Financial + Titan Wealth are taking it further with platform-as-a-service flexibility, giving firms room to plug in AI tools of their own.

The message? These aren’t pilot projects anymore. They’re early signs of AI becoming part of the advice architecture– less about shiny new tools, more about smoother, smarter systems.

3 | Where AI is already proving useful

A few real-world examples show where AI is already earning its place:

But let’s not gloss over the caveats – hallucinations, data privacy, and regulatory limits still need careful handling. Used well, AI could raise standards. Used badly, it risks confusion at scale.

4 | Four questions to ask before you jump in

If you’re thinking about introducing AI to improve clarity, start by asking:

1️⃣ Where are clients getting stuck? Is it in benefit summaries, decumulation options, or tax explanations? Start where misunderstanding costs the most time.

2️⃣ Do your systems talk to each other? AI is only as smart as the data it can reach. If your tools aren’t connected, your AI will be guessing in the dark.

3️⃣ What’s your “human handover” rule? Decide early when a person should step in – and make sure that’s logged, not left to chance.

4️⃣ How will you measure understanding? Track feedback, rewording requests, and drop-off points. They’re gold dust for continuous improvement.

AI should assistadvice, not automate it. The moment clients feel “talked at” instead of “spoken with,” we’ve missed the point.

5 | The regulatory line is still forming

Right now, there’s a healthy debate about whether AI explanations could ever count as “advice.” The FCA’s watching closely – especially as the 2026 pensions dashboards start taking shape.

Experts are already urging boards to build AI governance policies: define your scope, set guardrails, and make sure accountability stays human. The PLSAhas echoed that message – cautious optimism, yes, but oversight must stay front and centre.

Final thoughts: yes – but only if we build it well

So, could AI make pensions intelligible for all? Yes – if we let it translate, not replace.

AI won’t remove complexity, but it can help bridge the gap between technical language and human understanding. Done right, it can make advice land– turning jargon into clarity, curiosity into confidence.

The real test isn’t whether AI can talk. It’s whether clients trust what it says.

If that’s the challenge your firm’s exploring, we’d love to hear how you’re approaching it – no pitch, just a shared curiosity about doing advice better.

This month, the FCA reminded us – again, that proving compliance isn’t enough. It’s not about showing you followed a process; it’s about showing the process worked.

From pension lump sum cancellations to behavioural decision making in investment advice, the regulator’s latest activity is pointing to one clear direction: firms must be able to evidence good outcomes, not just intend them.

In this edition, I’ve summarised the key regulatory movements and what they mean for firms building advice that’s both compliant and defensible.

1. Pension Lump Sums: Clarity Over Convenience

The FCA’s latest statement on tax-free pension lump sums underlines how clarity and timing of communication remain under scrutiny.

Clients must be told, clearly and early, about their cancellation rights when accessing tax-free pension cash. This might sound procedural, but it cuts to the core of Consumer Duty – ensuring clients can make informed decisions, not just sign compliant paperwork.

If your firm uses templated pension communications or scripted processes, it’s worth reviewing:

• When and how cancellation rights are explained.
• Whether the language used matches the client’s understanding.
• How that understanding is evidenced in the file.

Because in 2025, intent isn’t enough – evidence is everything.

2. CP25/17: Behavioural Oversight Is the Next Frontier

The FCA’s Consultation Paper CP25/17 signals a growing focus on the behavioural side of consumer decision-making.

The consultation explores how firms present information, the sequencing of options, and the role of framing in client understanding. It’s another sign that “clear, fair, and not misleading” is evolving into “clear, understood, and evidenced.”

This shift has practical implications:

• Advice documentation should show how recommendations were presented and interpreted – not just the technical justification.
• Internal reviews need to track behavioural indicators such as overrides, deferrals, or drift from client objectives.
• Governance frameworks must demonstrate that behavioural risks are actively managed, not assumed away.

In other words, Consumer Duty has moved from paperwork to psychology.

3. The Bigger Picture: Governance and Accountability

According to Grant Thornton’s weekly regulatory insight, the FCA’s ongoing communications this quarter consistently tie back to governance evidence.

Boards are being encouraged, or required, to demonstrate how senior management systems (SYSC) translate into real-time oversight. Under SM&CR, defensible delegation depends on showing that advice risk is identified, monitored, and resolved – not just that a policy exists.

We’re seeing many firms move from static QA to what we call active assurance: live suitability scoring, override analysis, and version-controlled logic. It’s the difference between being compliant on paper and being confident under audit.

4. Suitability: Still the Linchpin

Every regulatory thread – Consumer Duty, PROD, SYSC, or COBS – eventually comes back to suitability. But suitability today is less about justification and more about defensibility.

As we explored in our recent Advice Integrity white paper, the question isn’t “Can you show why this advice was suitable?” It’s “Can you prove it was suitable the first time?”

That mindset shift requires:

• Structured, versioned advice logic.
• Measurable evidence of client understanding.
• Integrated adviser–consultant collaboration before QA even begins.

At We Complement, our Suitability Consultants are already embedding these frameworks – ensuring firms aren’t just compliant, but audit-ready by design.

5. Practical Takeaways for October

If you’re reviewing internal processes this month, here are three simple but high-impact checks:

1. Audit your pension communications. Are cancellation rights clear, accurate, and captured as evidence of understanding?
2. Test a recent advice file under Consumer Duty lens. Would a third party conclude the client’s decision-making was genuinely informed?
3. Review your management information (MI). Are you tracking behavioural indicators – such as override rates or objective drift – in a way that feeds back into governance learning?

These aren’t tick-box tasks; they’re the mechanics of modern integrity.

6. Why This Matters

The FCA’s narrative has become unmistakable: process without proof is no longer protection.

Good governance isn’t reactive; it’s built in. The firms that thrive under this evolving regime will be those that move from “checking” to “evidencing.”

As advisers, paraplanners, and suitability consultants, our collective role is to make that evidence feel natural – embedded, not bolted on.

That’s how trust is rebuilt. That’s how integrity becomes the norm.

If this resonates with what you’re seeing in your firm, we’d love to hear from you. No pitch – just people who get financial advice, trying to make sense of what the FCA really means by “good outcomes.”

War, Energy, and the New Fragility in Supply Chains

This summer has been a reminder of how fragile the global investment environment remains. Conflict and instability in Eastern Europe and the Middle East continue to ripple into energy prices, and the knock-on effect for UK investors is real.

The challenge for advisers is balancing client portfolios against this backdrop of energy vulnerability and disrupted supply chains. For many, the lesson is diversification: resilience doesn’t come from betting on a single sector, but from blending exposures across asset classes and geographies.

Professional Paraplanner recently underlined this point – fragility isn’t going away, so portfolios must be designed to flex with events rather than try to predict them.

High Turnover Strategies – A Contrarian Defence?

Another theme sparking debate is the value (or risk) of high turnover strategies. The conventional wisdom is to minimise churn to keep costs and tax drag low. But some managers argue that in volatile conditions, an active, nimble approach can add value.

The question advisers need to ask: is this discipline or reaction? Turnover in itself isn’t a strategy – it must be paired with a clear rationale, whether it’s capturing opportunities in shifting markets or mitigating downside risk. As ever, transparency on cost and risk to clients is the priority.

TIME:Advance – A Case Study in Investor Confidence

One of the standout updates this quarter has been from TIME:Advance, which continues to set itself apart in the Business Relief (BR) market.

• Top independent rating retained – Martin Churchill’s 2025 report again placed TIME:Advance as the most highly rated BR provider, noting their avoidance of leverage in renewables and their external valuations via BDO.
• £1.5bn AUM milestone – Assets under management have surged 50% since 2023, underlining both investor demand and confidence in the proposition.
• Rights Issue top-up window – Existing investors can still participate until 17 October (with cheques due by the 15th). Importantly, shares are backdated to the original investment date, which could qualify immediately for BR relief.
• Structured CPD webinars – Their “When BR…” series has attracted over 1,000 sign-ups, reflecting adviser appetite for practical CPD.

Behind these milestones sits a wider story: HMRC’s IHT receipts are soaring. In just the first five months of 2025/26, collections hit £3.7bn, up 5% year on year. Forecasts suggest receipts could exceed £9bn this year and £14bn by 2029–30. Frozen thresholds and rising asset values mean the pressure is only increasing.

For advisers, the question is less about if clients are exposed to IHT, and more about how quickly the exposure is growing.

Market Movers

It’s not just inheritance tax shaping the landscape. UK retail investors withdrew £1.8bn from funds in August, a sixfold increase from the prior month. Whether this is tactical repositioning or deeper nervousness remains to be seen – but it reinforces the need for advisers to keep client communication clear, frequent, and evidence-based.

Practical Takeaways for Advisers

• Stress test diversification: Portfolios should be designed to withstand energy price shocks and supply chain volatility, not just short-term market dips.
• Interrogate turnover strategies: Ensure the rationale is clear and the cost/benefit transparent for clients.
• Engage with IHT planning early: Rising receipts are a wake-up call – Business Relief and estate planning solutions remain essential tools.
• Stay close to clients: With retail flows showing volatility, proactive communication is critical to client trust.

Final Word

At We Complement, our role isn’t to tell advisers what to recommend, but to help them frame advice that’s evidence-based, defensible, and clear for clients. Whether it’s BR planning, portfolio structuring, or suitability oversight, the goal is the same: advice that holds up in real life, not just on paper.

If this resonates with what you’re seeing, we’d love to hear from you.

– Paul

Why are advisers talking about racehorses?

Specialised investments tend to arrive in adviser conversations when clients bring them up first. Racehorses are one of those topics. A client may have inherited a stake in a horse, been offered a syndicate share, or simply be tempted by the glamour of racing.

But beneath the champagne and Royal Ascot headlines sits a business model that is high-risk, highly variable, and at times emotionally driven. For advisers and paraplanners, the question is simple: how do you help a client weigh up whether horse ownership or related investments have a genuine place in their financial plan?

The Economics of Horse Racing

The UK racing sector is not small. It contributes billions annually to the economy and directly employs tens of thousands of people . Yet, profitability is far from guaranteed:

• High fixed costs: training fees, stabling, vet bills, transport.
• Uncertain returns: even top-bred horses may never win a major race.
• Concentration risk: performance is tied to a single animal, with limited diversification.

According to Everything Horse UK, the gulf between prize money and costs means only a tiny proportion of owners see a consistent profit .

For clients, it’s important to stress: racehorse ownership is rarely an “investment” in the traditional sense. It is closer to a lifestyle choice with a speculative upside.

Routes into the Market

If a client is interested, what are their options?

• Full ownership: prestige and control, but also the full burden of costs and risks.
• Syndicates or partnerships: a more affordable entry point, spreading costs and offering a sense of community.
• Racing clubs: usually lower cost, but these tend to offer experience rather than investment returns.
• Equine-related businesses: training, breeding, bloodstock-each with their own risk profile.

Risk Profile: What Advisers Should Flag

When assessing suitability, a few themes stand out:

1. Liquidity – stakes in horses or syndicates can be difficult to exit.
2. Transparency – syndicates vary in how clearly they disclose costs and expected returns.
3. Volatility – performance is unpredictable; injury or underperformance can wipe out expected returns overnight.
4. Taxation – while winnings are typically tax-free for individuals, related business ventures (like breeding) may be treated differently.
5. Welfare considerations – reputational risk matters; clients increasingly care how animals are treated, and UK racing’s welfare standards are under scrutiny.

Where it Fits in a Portfolio

For most clients, the honest answer is: it probably doesn’t.

From a regulated advice perspective, racehorse ownership does not offer the diversification, defensibility, or liquidity that most portfolios require. At best, it sits in the “speculative” or “passion asset” category akin to art, wine, or classic cars.

That doesn’t mean advisers should dismiss it out of hand. Instead, positioning it as:

• A lifestyle purchase: something clients do for enjoyment, status, or community.
• Not core wealth: it should never replace mainstream diversified investments.
• An emotional decision: acknowledge that non-financial returns (excitement, involvement, prestige) may outweigh financial logic.

Practical Pointers for Advisers

If a client raises this area, here are three practical steps:

• Frame expectations early – make clear that this is high-risk and unlikely to deliver reliable returns.
• Document suitability carefully – especially under Consumer Duty. Make sure client objectives (fun, experience, prestige) are stated explicitly.
• Signpost reputable sources – direct clients to industry overviews like British Horseracing Authority’s welfare standards and investment explainers like Niche Racing.

Bigger Picture: What This Teaches Us

Even if your client never invests in a horse, the topic is a useful reminder:

• Clients are influenced by lifestyle trends, not just markets.
• Suitability isn’t just about returns; it’s about aligning advice with personal goals, however unconventional.
• Specialist investments can spark valuable conversations about risk appetite, liquidity, and diversification.

Sometimes, leaning into the “fun” examples-like racehorses-can make more serious portfolio principles easier to explain.

Final Thoughts

Racehorse ownership will never be mainstream. For most, it’s an indulgence, not an investment. But it is part of the wider landscape of “passion assets,” and advisers who can engage with it knowledgeably strengthen their position as trusted guides.

If a client asks you about it, the best response is rarely a blunt “no.” Instead, it’s a balanced conversation: respect the excitement, explain the risks, and keep the financial plan grounded.

Recognition matters – but not just for job titles

Over the past week, FT Adviser ran a piece on whether paraplanners should be formally recognised by the FCA. It struck a chord.

Should paraplanners be formally recognised by the FCA?

Because here’s the thing: this isn’t really about job titles. It’s about how the profession sees suitability assurance – the discipline of testing, evidencing, and proving advice before it ever reaches the client.

At We Complement, we see this every single day. Suitability assurance isn’t an afterthought. It’s what gives advisers confidence, helps clients actually understand the jargon, and shows regulators that firms are delivering Consumer Duty in practice. That’s why we’ve taken the role further with Suitability Consultants – not just writing reports, but shaping advice so it’s clear, structured, and defensible from the start.

Why leaving suitability to the end is a problem

Too often, suitability only shows up at the very end of the process – when the report’s drafted, the advice’s written, and the adviser’s already moved on. That’s where the pain starts.

• Adviser time gets eaten up: A Rathbones study, covered by Money Marketing, showed compliance is taking a big bite out of the time advisers actually spend with clients link. Retrospective QA is a huge part of that.
• Clients are lost in translation: A fifth of pension holders say they don’t understand a single pension term. If suitability reports don’t translate advice into plain English, then we’re not doing our job.
• Firms risk being on the back foot: Without formal recognition of suitability as a discipline, it can too easily be seen as a “nice to have.” That’s a dangerous place to be when the FCA is widening Consumer Duty to cover everything from pensions to crypto.

Suitability Consultants: more than just “paraplanners plus”

This is why we think the conversation about recognition doesn’t go far enough. A Suitability Consultant isn’t just a paraplanner with a shinier badge. The role has grown up.

Here’s how we see it:

• Forensic: challenging adviser inputs and testing logic against FCA rules before the advice ever gets near a client.
• Structured: using processes like Advice Readiness Checks (ARC) and Suitability Matrix Scoring so that every case is traceable, versioned, and audit-ready.
• Human: turning technical recommendations into plain, client-friendly language (because let’s be honest, if you can’t explain it without jargon, it probably won’t land).

In short: they’re not back-office support. They’re part of the infrastructure of advice integrity.

A few practical things firms can do right now

If you’re nodding along, here are three simple shifts you can make without turning your whole process upside down:

1. Start suitability earlier Don’t wait for QA to catch issues. Build suitability assurance into the advice construction stage. It saves rework and makes files more defensible.
2. Make clarity a non-negotiable Test whether your reports actually make sense to someone outside the profession. If a client can’t explain back the recommendation in their own words, we need to do better.
3. Treat suitability as strategic, not back-office The firms that are thriving under Consumer Duty aren’t those with the flashiest tools. They’re the ones that embed suitability as a front-line discipline.

So, should paraplanners get FCA recognition?

Probably. But I’d argue the debate needs to stretch further. It’s not just about paraplanners getting a formal nod. It’s about recognising that suitability assurance itself is too important to stay in the shadows.

Done well, it’s the thing that frees up adviser time, helps clients feel confident, and gives regulators the evidence they’re asking for. Done badly, it’s just more paperwork.

And nobody got into financial planning to drown in paperwork.

Final thought

This industry loves to talk about efficiency, but the bigger win is trust. Suitability assurance done properly builds both.

That’s what excites me about where the role is going. And if you’re also feeling the compliance drag, or you’ve got your own take on recognition, I’d love to hear it.

Big names in adviser tech are making headlines again. Aberdeen, Intelliflo and ZeroKey recently announced a new partnership, aimed at streamlining adviser technology and tackling inefficiencies across the sector (Money Marketing). Add to that the Carlyle Group’s acquisition of Intelliflo (Carlyle release), and it feels like adviser tech is consolidating faster than some advice firms.

But behind the M&A noise, one theme keeps coming up in our conversations with advisers and paraplanners: data openness. Because the reality is that slick partnerships mean very little if the data still doesn’t flow properly.

Why advisers are frustrated with data

According to NextWealth’s Data Openness report, most advisers see inconsistent and poorly structured data as one of their biggest operational headaches. Platforms and providers all have their own formats, delivery methods, and quirks. For smaller firms it’s annoying. For consolidators it’s a nightmare.

Here’s what we’re hearing:

• Data doesn’t flow cleanly between CRMs, platforms and back-office systems.
• Transfers drag on because information is incomplete or locked in PDFs. (Platforms Association)
• Advisers spend hours rekeying – which means less time with clients, and more chance of errors.

One consolidator quoted in the research summed it up bluntly: “Clients would be horrified if they knew what a shambles it is from different providers.”

The drivers for change

So why might this finally shift? Four main forces are pushing providers to get serious about data quality and accessibility:

1. Regulation & Consumer Duty – The FCA expects firms to prove ongoing suitability, not just tick boxes once a year. You can’t do that without reliable, consistent data.
2. Client expectations – Life doesn’t happen on an annual review cycle. Clients want real-time updates, not a paper pack once a year.
3. Private equity ownership – With investors like Carlyle putting significant capital behind platforms, the pressure is on to show scalable, data-driven infrastructure.
4. AI – Whether it’s report drafting, admin automation, or client portals, AI is only as good as the data it ingests. Garbage in, garbage out.

Where the innovation is happening

Across the market, we’re seeing a wave of new solutions designed to cut down on wasted admin and smooth advice workflows.

• AI-driven Letters of Authority tools are reducing the chaos of provider packs, extracting structured data and cutting turnaround times.
• Client portals are giving households access to valuations, tools and resources in real time – but only if the underlying data is clean.
• AI meeting assistants are helping capture, transcribe and summarise client conversations, turning them into ready-to-use notes and draft suitability reports.

The common thread? All of them depend on clean, structured, open data.

No matter how smart the AI, if it’s working with half-finished fact-finds, locked PDFs, and missing product histories, it can’t deliver the outcomes advisers and clients expect.

Practical steps for advice firms

If you’re sitting in an ops or compliance seat at an advice firm, here are some practical questions to put on your agenda:

• Ask your platforms: What data standards do you support? Can you provide structured feeds rather than PDFs?
• Challenge delays: If transfer times are holding back client outcomes, escalate it. The Platforms Association is already putting pressure on providers – firms adding their voice will speed things up.
• Audit your own systems: Are your back-office and CRM actually set up to receive and store structured data? Or are you still relying on manual workarounds?
• Think beyond today: If you’re experimenting with AI (drafting reports, summarising calls, or using portals), remember: the investment only pays off if the underlying data is trustworthy.

Why this matters for advice culture

This isn’t just about efficiency. It’s about trust.

We’ve argued in our Advice Integrity white papers that retrospective file checking is a broken model. Real-time, evidenced advice is the only way to satisfy the FCA, reassure insurers, and build public confidence. Data openness is the bedrock of that shift.

If advisers can’t rely on their data, they can’t prove their advice integrity. And if clients can’t get clear, consistent information, they won’t trust the advice profession to deliver.

The takeaway

Tech partnerships, private equity deals, and shiny AI demos will keep making headlines. But the firms that win in the next five years will be the ones that get their data house in order – demanding openness from providers, aligning systems internally, and using that foundation to power real-time suitability and client confidence.

If this resonates with what you’re seeing in your own firm, we’d love to hear from you.