Advice & Suitability

A newly qualified adviser posted in an adviser Facebook group recently, asking where they could find practical support now the exams were out of the way. It planted a seed with me, and I found myself going back the next day to read through the comments. They’d worked hard to get qualified, but what they were looking for now was help putting that knowledge into practice. The day-to-day side of actually doing the job.

I’m not an adviser, so I’m coming at this from a slightly different perspective. But through my work at We Complement, I spend a lot of time talking to advice firms about how they operate, and it’s made me think about what helps someone develop from being newly qualified into a really good adviser.

What an exam can’t do

Academies and qualifications do a proper job. They get people through some hard exams and give them a solid grounding in regulation and financial planning. What an exam can’t do is put a real person in front of you.

Real clients don’t arrive as case studies. They might not be sure what they’re asking for. They might have a business, a mortgage, a daughter at university and a parent they’re worried about, and the thing that matters most to them might only come out as you’re putting your coat on.

The skill I’d put near the top of the list is starting the right conversation. That means asking someone what they want their future to look like before you get anywhere near a pension or an ISA, and then properly listening to the answer. It might also mean understanding who else is important in their life and, where it’s appropriate and the client wants them involved, bringing those people into the conversation. A partner, children or sometimes parents. Financial decisions rarely exist in isolation, and understanding the wider picture can make all the difference.

Do that well over a few years and you stop being the person who sends a report once a year. You become someone the client trusts with some of the biggest decisions in their life. That doesn’t arrive with the certificate, and I don’t think it should be expected to. It comes from experience, seeing how different conversations unfold, asking questions and learning from people who’ve been doing it for years.

You can see it in the file

When you work with a lot of firms, you notice how much of an advice file goes back to the conversation that came before it. A fact-find is only as good as the questions someone asked.

If the conversation was a good one, the objectives tend to be clear and specific, and everything after that gets easier. If it was a bit thin, somebody further down the line ends up filling the gaps. That usually means the adviser going back to the client, or the technical planning team asking for more information before they can move forward.

It’s not necessarily about anyone doing a bad job. Sometimes it’s simply experience, knowing which questions to ask, when to dig a little deeper and when something needs exploring further. And that’s exactly the sort of thing that’s difficult to learn from a textbook.

Everyone has a part to play

Academies lay the foundations. Firms provide the opportunity to put that knowledge into practice, with real clients and real situations. And experienced advisers, technical planners and other specialists all have something they can share. I think there’s a real opportunity for those different parts of the profession to work more closely together, particularly when someone is finding their feet.

Passing your exams is a huge achievement, but it’s also just the beginning.

Where we come in

We’re not usually in the room when those client conversations happen, but we see the difference they make to the work that follows. We know what happens when a fact-find gives the technical team everything they need, and we also know the questions that tend to come back when something important is missing.

It’s made me think there’s a useful conversation to be had with adviser academies about what happens after qualification. Could we help newly qualified advisers understand what makes a good fact-find from a technical planning perspective? Not just which boxes need filling in, but why certain information matters and how it affects the advice that follows.

I’d really like to explore putting together a practical guide or session around that, particularly with academies or firms who are already supporting people through those early stages.

It’s also where having experienced technical support available can make a difference. Whether that’s helping with research, working through more complicated cases or picking up questions before the advice is finalised, there’s value in having people to turn to while confidence and experience develop.

You can find out more about how We Complement supports advice firms here.

And if you run an academy, manage an advice team or remember what those first few months as an adviser felt like, I’d genuinely love to hear your thoughts.

What do you wish had been available once the exams were over?

A client is approaching retirement with several pensions. Bringing them together would make withdrawals easier to manage, but one existing plan has competitive charges and features worth keeping. The adviser has a preferred approach and sound reasons for it. The research supports much of their thinking, although there is still a decision to work through.

This is where a conversation between experienced colleagues earns its time. Both approaches have merit. The task is to establish which benefits matter enough to this client to justify the compromises involved.

The advisers we work with value having someone to explore that with. They bring their understanding of the client and explain how they have reached their view. We examine the arrangements in detail, investigate the alternatives and talk through what the findings mean for the recommendation. Often, the most useful part is a discussion about something neither a comparison table nor a product description can settle.

What does simpler mean for this client?

In the pension example, “easier to manage” needs some context. A client who is comfortable dealing with several providers has different priorities from someone who finds the paperwork overwhelming. There is also a difference between wanting a tidier annual statement and needing a withdrawal arrangement that the client and their partner can manage confidently throughout retirement.

The research can then test whether keeping the low-charge plan and consolidating the others would provide the practical benefits the client needs, while preserving features worth retaining. That means comparing the costs, benefits and options before combining pensions, including whether a partial consolidation would serve the client better than a full move or leaving the arrangements as they are.

Two clients with similar pension values, retirement dates and attitudes to risk can reasonably receive different recommendations. The explanation needs to show which circumstances tipped the balance.

What would make us favour the alternative?

Once an approach looks sensible, it is easy to concentrate on developing it. There are illustrations to obtain, calculations to complete and practical details to confirm. Before getting too far into that work, I find it useful to ask what would make the other option preferable.

Take a client attracted to flexible withdrawals who expects to take the same income every month. Flexibility could still matter, particularly for future expenditure or changes in circumstances. But its value needs exploring before it becomes a central reason for recommending a more expensive arrangement. If the client has no foreseeable need to vary withdrawals, that deserves a place in the discussion.

Working through that point helps establish how much weight the feature should carry. It can strengthen the original recommendation or bring another approach into consideration. Either outcome is useful because we have examined something capable of affecting the decision.

When the recommendation stays the same

A second perspective does not have to produce a different answer to be valuable. Sometimes the research and discussion confirm the adviser’s original view, having tested it against a credible alternative.

The proposed transaction is unchanged, but the adviser has more to draw on when explaining it. A lower-cost option has been considered properly, an existing benefit assessed or the possibility of achieving the objective without making a change explored. For those managing advice businesses, that is a contribution worth recognising alongside completed cases and turnaround times.

Could a colleague see why we chose this?

By the end of a case, the adviser and suitability consultant usually understand why one approach was chosen. Some of that understanding can remain in conversations and emails rather than making it into the explanation the client receives.

A report that describes flexibility or ease of administration needs to connect those features to the client’s plans. Where a higher cost has been accepted, the benefit justifying it should be clear. Where an existing arrangement is retained, the reasoning should explain why the alternatives did not offer enough improvement.

Writing this down is a useful test. If the explanation is difficult to make specific, there may still be a point to resolve. It also gives a colleague reviewing the advice later a clearer understanding of what the recommendation depended on, particularly if the client’s circumstances have changed.

At We Complement, that exchange with the adviser is central to our suitability consulting work. It gives us the opportunity to contribute while the options are being considered, and then carry the reasoning through into the report.

When two approaches are credible, could someone reading the file understand why one was chosen and what would have made the alternative preferable?

Written by Paul, Managing Director

A look at keeping the reasoning behind a recommendation in the file, long after the suitability report has gone out.

Most advisers could find the suitability report for a client they advised six months ago without much trouble. Whether somebody else could pick up the whole file and work out why that recommendation was made at the time is a different matter.

The report explains the recommendation to the client. The reasoning behind it is often scattered across meeting notes, research, emails, cashflow modelling, fact-finds, provider information and conversations between the adviser and technical planner. The recommendation itself may be perfectly clear, but if the thinking isn’t captured while the advice is being constructed, somebody returning to the file later ends up piecing the story together from the finished report rather than seeing the decision as it was made. At the time, all of that context feels obvious. Six months on, it usually doesn’t.

That sits behind Tony’s fourth paper in our Advice, Evidence & Judgement series, which argues that a good advice file should preserve the decision as well as the final recommendation. As he puts it, six months later the firm shouldn’t have to invent the reason again. It should be able to produce the one that was actually used.

Could somebody else follow the decision?

A useful test is to imagine the original adviser isn’t available. Could another competent person look at the file and identify the important evidence, understand any tensions or uncertainty, see which alternatives were genuinely considered and follow the judgement that led to the recommendation? They don’t need every thought that went through the adviser’s head, just enough to understand the decision path.

In practice the questions are fairly simple. Which client facts actually mattered, and was there anything that didn’t fit neatly? Why was this option chosen, and was another serious option considered and rejected? What was challenged along the way, and who adopted and signed off the decision in the end?

Tony calls this the six-month test: take completed cases old enough for memory to have faded and ask somebody who wasn’t involved originally to reconstruct the decision from the file alone.

When the reasoning gets recorded

The paper makes a useful point about timing. If the rationale is only written once the suitability report is being drafted, there’s a risk the explanation is being built around a recommendation that has already been decided. That happens easily, because once you know the answer, a neat account of how you got there is simple to produce.

A stronger sequence is to pull the evidence together, identify anything that conflicts or remains uncertain, record the important judgement and resolve any challenges before the client-facing report explains the recommendation. None of that means pages of extra notes. A short working note that captures the main trade-off can be worth more than a huge file where nobody can tell which facts drove the advice.

Think about who inherits the client

You might remember today exactly why a recommendation made sense, but you may not be the person looking after that client in two years’ time. A colleague could inherit the relationship, a manager might need to review a group of similar cases, the client could query an old decision, or someone dealing with a complaint may need to know what was understood when the advice was given. The FCA’s review of ongoing advice services, which had firms looking back over several years of client records, is a reminder that files get read long after the advice was given. A well-built file makes that person’s job easier because the documents are there and so is the route from them to the decision.

Five cases is enough to learn something

This doesn’t need to become a big project. Take five older completed cases and give them to somebody suitably experienced who wasn’t involved at the time. Ask them to explain back what mattered, where the uncertainty was, why you recommended what you did, which alternative you seriously considered and what was challenged.

If they can answer without speaking to the adviser, the file is probably preserving the reasoning well. If they keep having to ask the adviser to fill gaps from memory, you’ve learnt where the reasoning is actually being kept.

There’s a stage in an adviser’s career that seems to get much less attention than the exams that come before it. You’ve done the studying, passed the exams and you’re working towards being able to advise independently. On paper, there’s a route through qualification and Competent Adviser Status, but in practice the bit where you actually learn how to do the job is much less straightforward.

Knowing the technical answer is one thing. Sitting in front of a client and knowing which questions to ask, when to probe a little further, how to deal with a conversation that goes off in a direction you weren’t expecting, and what information the rest of the advice team will need from you afterwards is something completely different. That part comes with experience, and how much support you get while you build that experience can depend a lot on the firm you join.

Some larger firms have built a lot of structure around that journey. They have academies, mentors, supervised client work and experienced people whose job it is to help new advisers develop. Smaller firms can offer brilliant experience too, and in some ways a new adviser may get more exposure to the whole business, but they don’t always have the same infrastructure sitting behind them. Often, the person doing the mentoring is also running a client bank, managing staff and trying to keep the business moving.

That’s the part I’ve been thinking about lately. When a firm takes on someone who is still developing, those early cases naturally need more time and attention. There are more questions, more checking and more conversations around why something has been done in a particular way. That’s exactly how it should be, but it can put pressure on the people around them, particularly in a smaller business where there may only be one or two experienced advisers available to provide that support.

It made me wonder whether there’s a role for We Complement in the work that sits around development, without stepping on a firm’s own training and competence arrangements or getting anywhere near CAS sign-off.

The fact-find is one obvious example. Our team sees what happens to a case once the client meeting is over. We see which gaps in information lead to more questions later, what makes a file straightforward to research and write, and what tends to result in somebody having to go back to the adviser for more detail. It’s a view of the advice process that newly qualified advisers don’t always get to see, and I think there could be real value in sharing some of that earlier.

That doesn’t need to become another formal training programme or compliance checklist. It could be as simple as showing someone what a strong fact-find looks like from the point of view of the person picking it up afterwards, and explaining why certain details matter. It might work as a short guide, a session with an academy cohort or something more informal for a group of advisers who are still finding their feet.

There’s also the wider capacity issue. If an experienced adviser is spending more time mentoring and reviewing early cases, something else in the business still needs to get done. Paraplanning, research, processing and admin don’t disappear while someone is developing. That’s where I can see a role for flexible support, helping to take some of the pressure elsewhere so the people inside the firm can spend their time where it’s most valuable.

I’ve been looking at how different firms approach this, from larger academies through to newer propositions such as Evergreen, and there clearly isn’t one model that works for everybody. I also came across a Money Marketing piece on Competent Adviser Status which makes the point that qualification is only one part of the journey. The practical experience that follows matters just as much, which feels obvious when you work in advice, but perhaps less obvious from the outside looking in.

What I keep coming back to is the smaller firm that wants to develop its own next adviser but doesn’t have an academy sitting behind them. We don’t have a finished answer to that, and I don’t really want to invent one from our side of the desk. I’d much rather understand what firms and advisers actually find difficult during that stage and see whether there’s something useful we can build around it.

So if you run an academy, mentor advisers working towards CAS, or you’re a smaller firm developing someone new, I’d really like to hear what that experience looks like for you. And if you’ve been through it yourself in the last few years, what’s the one thing you wish somebody had shown you earlier?

More than one adviser has told us the same thing recently. Their annual reviews are deliberately booked into the same few weeks every year. Ten, fifteen, sometimes twenty reviews, all planned that way well in advance. And actually, it makes a lot of sense. Once a review is booked, it tends to stay exactly where it is. Advisers protect that hour, and rightly so, because it is the part of the process the client actually sees.

What is harder to protect is everything built around it: provider information gathered, valuations chased, client records updated, files prepared, any technical work completed, recommendations implemented, and someone making sure it all actually gets followed through. One review at a time, spread across the year, that can feel manageable. Ten of them landing together is a different problem, and it is bigger than it looks on paper.

Put a number on it

Across the review work we support, a fairly standard case will often involve around five hours of admin and paraplanning time in total, split either side of the meeting itself. Roughly two hours might go on admin beforehand, gathering provider information, pulling valuations and preparing the file. After the meeting, report writing and paraplanning can take around another two hours, with implementation and updating records adding roughly another hour.

Ten standard reviews booked into the same month therefore means around 50 hours of admin and paraplanning work landing around those meetings, on top of whatever else is already sitting with the team. Even that understates it, because a review is not one task, it is a sequence: gather, prepare, meet, report, implement, chase. Each stage depends on the last one finishing, so once several reviews are moving through the process at once, they start to queue behind whichever stage is slowest.

That is often where the real problem sits. Ten reviews rarely feel like ten times the work. They feel like everything backing up behind one narrow point while the meetings booked months ago carry on regardless.

Why batch them at all?

There is no one right way to structure annual reviews. Some firms spread them across the year, while others deliberately work in surges and group them into known periods. Both can work. The real question is whether the rest of the process has been designed around that choice and whether anyone is actually watching where the queue builds.

The hours do not always tell you where the problem is. The gaps often do. How long does a case spend waiting for a valuation, waiting for technical work, or waiting to be implemented compared with the time someone is actually working on it? That waiting time can quickly become the real capacity problem.

A useful way to test your own process is to look at the last five reviews you completed. Do not just record how many hours they took. Look at how many days passed between each stage and where each case spent the longest waiting. If every case spends three days waiting for provider information, adding another paraplanner will not necessarily solve the problem. If everything reaches the same technical reviewer at once, speeding up the admin beforehand might actually make the queue worse.

Where we actually fit

We do not think every firm needs to run annual reviews the same way. Some want help with the whole process. Others only need support with provider information, report writing, implementation, or just the weeks where workloads spike.

We have never been in the room for the review meeting itself, and that is deliberate. That is the adviser’s conversation to have. What we can do is support the work around it, from arranging the meeting and gathering information beforehand through to suitability work, implementation and follow-up after. Our annual review service was built around exactly that split. Some firms hand us most of the process, while others only hand over the part that is creating the bottleneck. Either way, the adviser keeps the client relationship.

It is not always about how many reviews you have

The more annual review conversations we have, the less I think the interesting question is “how many reviews do you have?” and the more it is “how much of each review still sits with the adviser?”

A firm can have a perfectly manageable number of reviews on paper and still feel stretched if the adviser is carrying the preparation, technical work, meeting, documentation and follow-up alone. If reviews are already planned months in advance, that is also the moment to decide who does each part of the work, before the batch lands rather than during it.

If your reviews are already scheduled in one batch every year, which stage backs up first once that window opens: the admin before, the paraplanning after, or the implementation and records once it is all agreed?

So, being the geek that I am, the first thing I did at 6:30 this morning, after the cat woke me up at 5:30 wanting to go outside and kill things, was download the NextWealth Financial Advice Business Benchmarks Report 2026.

There are probably more exciting ways to start a Friday, but one figure in the “people and capacity” section really caught my attention.

NextWealth says onboarding a typical client takes around 32 hours of human time across the whole team. Of that, admin accounts for eight hours and paraplanning for seven, so 15 hours combined before adviser and compliance time is added in.

We do exactly that slice of the work for a living, so naturally I wanted to know what our own numbers looked like.

What our own data says

Because we track time against the work we do, I was curious to see what our own numbers looked like next to the NextWealth benchmark. Across our casework this year, (631 cases and counting) our average admin and paraplanning time comes out at around 6.8 hours per client.

On the face of it, that’s less than half NextWealth’s 15-hour figure. But it isn’t quite a like-for-like comparison, and that’s actually where it gets interesting.

NextWealth’s figure relates specifically to onboarding a typical new client. Ours is a blended average across the different types of work firms send us, from more straightforward reviews and switches through to much more involved pension and specialist planning cases.

So I wouldn’t use 6.8 hours to claim we’re somehow “twice as fast”.

What I do think is useful is that we know our number at all. Because when you track the time properly, you start to see very quickly which work is taking longer, which types of case use the most capacity and where the hours are actually going.

The average hides a lot

That 6.8-hour figure is only useful if you remember it’s an average. Some of the more straightforward work we see can sit around the 4 to 5-hour mark. More complex planning cases, IHT work or pension cases with several moving parts can easily be much higher.

Neither end of that range is “right” or “wrong”. It’s just different work.

That’s probably one of the biggest problems with any single benchmark for paraplanning time. A straightforward review and a complex pension case can both be called a “case”, while the amount of work involved can be completely different. So for me, the more useful question isn’t whether your number is 6.8 hours or 15.

It’s whether you actually know what your own number is, and what sits behind it.

Why might our number be lower?

This is the bit I’d be careful not to overstate. I don’t think our data proves that outsourced paraplanning is automatically faster than an in-house team, because it doesn’t.

But specialisation probably plays a part.

Our team spends most of its working week doing this type of work across different firms. Research, suitability reports, reviews, pension cases, investment work. It is the main job rather than one task competing with everything else that lands that day.

One thing we do see is the effect of interrupted work. If someone is researching a case while also dealing with client queries, internal meetings, admin, system issues and whatever else has appeared in the inbox, there is naturally more stopping and starting.

That’s not a criticism of in-house teams at all. There are brilliant internal paraplanning teams that will be every bit as efficient.

It’s simply one possible reason why a dedicated team doing the same type of work repeatedly might see a different average.

This is where the operational bit matters

For Heads of Paraplanning and Ops Managers, I think the more useful question is not:

“Should our cases take 6.8 hours or 15?”

It’s:

“Do we actually know how long they take?”

Because if you don’t know that, it becomes very difficult to work out where the pressure is really sitting.

Is a paraplanner spending five hours on technical work and another two on admin?

Is research being redone because information is missing?

Are advisers chasing providers when that work could sit elsewhere?

Is the team genuinely short on capacity, or is too much time disappearing into work that doesn’t need to sit with them?

That’s the sort of thing we end up talking through with firms all the time. And because most of our work is charged hourly, we get a pretty clear view of it.

Our paraplanning and technical support is currently £75 + VAT per hour, while admin support is £55 + VAT per hour.

That means both we and the firms we work with can see what different parts of the process are actually costing in time, rather than just looking at one overall salary or cost figure.

Cost to serve is becoming a much bigger conversation

The wider NextWealth report backs that up. 40% of firms have reviewed the cost to serve a typical client in the last 12 months, and another 25% plan to. The report also shows firms making much more deliberate decisions around which clients they serve, how they serve them and what those relationships actually cost.

That’s probably the bit I think is most useful for business owners.

You can know your revenue per client down to the pound, but if you don’t know how many hours of adviser, paraplanning, admin and compliance time sit behind that revenue, the picture is still incomplete. And the same applies to growth.

More clients only works if the delivery model underneath them can actually cope.

The bit I’d check in your own numbers

If you head up paraplanning, run operations or own an advice firm, I think this report is a pretty good prompt to pull your own data.

Not because you need to beat 15 hours.

And not because 6.8 is some magic target.

But because your own number tells you something useful about how your business is actually working.

I’d be looking at average research and paraplanning hours by case type, rather than one blended total. I’d also want to know how much technical time is being lost to admin or chasing, and whether the same people are regularly doing work below their skill level because there is nobody else available to pick it up.

That’s where the interesting conversations usually start.

Money Marketing’s coverage of the report picked up on the same wider theme, with firms repricing and segmenting client books as cost-to-serve becomes more important.

And the full NextWealth Financial Advice Business Benchmarks Report is well worth a look if you work in operations, paraplanning or run an advice business.

Where I land on it

I’m not the one logging the time against every case. That’s down to the team and the system they use. But I do like being able to put our own numbers next to a national benchmark rather than just saying “we’re efficient” and expecting people to take our word for it.

Our 6.8 hours doesn’t prove we are faster than everyone else. What it does show is that we know what our work takes, we track it properly, and we can see how much the answer changes depending on the type of work involved.

That feels like a much more useful conversation to have with firms.

If you want to see what outsourced research and paraplanning looks like against your own case volumes, we’re always happy to put real numbers on the table.

Ours and yours.

I’m not a paraplanner. I don’t write suitability reports, and I wouldn’t pretend to know what should go in every section of one. But I talk to a lot of people who do, and there’s a slightly awkward question that comes up more often than you might think.

A suitability report is usually read properly by the paraplanner who wrote it, the adviser who checks it and, depending on the firm, compliance too. What is much harder to know is how much of it the client actually reads. From the conversations we have with firms, there’s often a suspicion that clients focus on the summary, the recommendation and the cost, rather than reading every page from beginning to end.

That isn’t a criticism of clients. Most people do not want to spend their evening reading page after page about their own circumstances in language they do not use every day. What they really want to understand is fairly simple: did you understand my situation, what are you recommending, why, what is it going to cost me, and do I trust the advice?

So who is the report actually for?

The truth is, it is doing two jobs at once. It has to help the client understand the recommendation in front of them, and it also has to create a clear record of why that recommendation was suitable.

Both matter. The problem starts when the second job begins to overwhelm the first.

We see this most clearly when we start working with firms that have been using the same report template for years. A paragraph gets added after one case. Another gets added later because something once felt like it should have been covered. Then a disclosure appears because someone worries it might be needed one day. None of that is bad practice. Usually, it comes from a perfectly reasonable desire to make sure nothing gets missed. But over time, the report grows, and it’s often not until a new firm sits down with us and sees their own template laid out fresh that they notice quite how much it’s grown. More than one has told us that they’d rather start again with ours than keep adding to their own.

How reports gradually get longer

At some point, it becomes worth asking whether every section is still helping this particular client understand this particular recommendation. That is often part of the early work we do with firms through our suitability consulting support, not cutting things just for the sake of making a report shorter, but asking what each section is there to do and whether it still earns its place.

Because client understanding is not the same thing as information volume.

That is close to what the FCA’s Consumer Duty guidance on consumer understanding is getting at too. The aim is not simply to disclose information, but to communicate it in a way the customer can understand, at the right time, so they can make an informed decision.

Client understanding vs evidence

Some cases absolutely need detail. Some clients want more explanation than others. There will always be parts of the file that exist because the advice needs to be properly evidenced.

But pretending every paragraph is there for exactly the same reader, doing exactly the same job, probably does not help anyone.

A good suitability report should be able to do both: explain the advice clearly to the client and evidence the reasoning properly for the file. The challenge is making sure one does not drown out the other.

If a client read the whole thing, would they understand it, or would they just feel like they’d been told something very thoroughly?

Sound familiar? Whether it’s a template that’s grown well beyond what any client actually needs, or a nagging feeling that nobody’s quite sure who the report is written for anymore, it might be worth a second look. We’re always happy to talk it through, no obligation, just a conversation about what’s actually needed and what isn’t.

On 13 July 2026, the DWP and the FCA published an updated consultation on a Value for Money framework for workplace pension schemes, focused initially on default and quasi-default defined contribution arrangements. It’s built around comparing schemes on cost, investment performance and service quality together, rather than cost alone. The consultation closes on 1 September 2026, with the FCA expecting the first larger schemes to complete assessments from 2028, and broader rollout from 2029.

My first reaction was that this felt like a workplace pensions story, not an advice story. It largely still is. The framework is aimed at scheme operators, trustees, independent governance committees and employers, not at individual advice recommendations. But the more conversations I’ve had about it, the more I think the information it eventually produces is worth advisers keeping an eye on.

CP26/25: The Value for Money Framework: consultation

Why this might still matter to advisers

Cost has always been a relatively easy thing to justify in a suitability report. It’s a number. Either the charges are competitive or they’re not, and that’s simple to evidence. Value is a different kind of judgement, made up of things that are harder to reduce to a single figure: how a scheme’s investments have actually performed, how responsive the provider is, whether members get the support they need when something goes wrong.

The framework is not an adviser suitability rule, and it does not automatically mean a scheme with a weaker rating is unsuitable for an individual client. But once more comparable value information exists across workplace schemes, it may become another piece of evidence firms need to consider and interpret, particularly where a workplace or legacy arrangement forms part of a wider recommendation.

That’s the interesting part, for me. Not a new rule, but a new source of evidence that didn’t really exist in this form before.

What’s worth doing now

• Start noting the reasoning behind scheme and provider recommendations in more than cost terms, even informally, so there’s a trail to point back to later.
• If your firm runs a centralised retirement or investment proposition, take a proper look at how each element would hold up against cost, performance and service, not cost alone.
• Keep half an eye on how the framework’s ratings actually get published as it rolls out from 2028 onward. A scheme that looks fine today could be rated differently once the comparisons exist.
• Consider how your research and review processes would use future published value assessments where a client’s workplace or legacy arrangement is relevant to the advice.

None of this is about second-guessing recommendations that have already been made, or assuming every legacy scheme needs revisiting because of this consultation. It’s about building the habit of capturing why a scheme was considered good value at the time, so that reasoning is there if it’s ever needed.

The framework is primarily a workplace pensions reform, still some years from full rollout. But the information it creates could eventually influence research, review processes and the way firms evidence decisions involving existing workplace arrangements, even without becoming a suitability rule in its own right.

As these value ratings start to appear over the next few years, what would you want to see change first in how your firm researches workplace schemes?

If you’d like to learn more about how we support financial planning firms with suitability consulting, annual reviews and operational support, you’ll find more information here:

Services

A while back, I wrote about how every firm we work with seems to run its annual review process slightly differently. The same consultation proposing changes to what counts as sufficient information (see last week’s issue) is also proposing that firms should instead offer periodic reviews at a frequency reflecting the client’s needs, rather than a fixed annual one.

On paper, that sounds like flexibility. In practice, it’s a new decision a firm now has to make, and be able to explain.

Why “periodic” is harder than “annual”

An annual review has one big advantage: nobody has to think about it very hard. The date comes round, the review happens. It isn’t necessarily the right cadence for every client, but it’s simple, and it’s consistent.

Periodic reviews remove that simplicity. If the frequency is meant to reflect the client’s actual circumstances, someone has to decide what those circumstances call for, and then be able to explain why. A client in drawdown, relying on the portfolio for income, probably needs checking in on more often than someone twenty years from retirement with a straightforward pension. That much is obvious. What’s less obvious is how a firm decides, consistently, where every other client sits in between.

And once that decision exists, it needs the same discipline the annual review used to get automatically. If a client goes eighteen months between reviews instead of twelve, was that decided deliberately, based on their situation, or did it just happen because nobody flagged it?

What’s worth thinking about now

• Look at how review frequency actually gets decided today. Is it genuinely need-based already, or has “annual” been doing the thinking for you?
• Build some simple criteria for what pushes a client toward more frequent reviews. Drawdown, vulnerability, recent life changes and volatile portfolios are the obvious starting points.
• Document the reasoning per client, not just the date. “Reviewed every 12 months” and “reviewed every 12 months because of X” are very different things to show a regulator, or a new adviser picking up the file.
• Think about capacity. If review frequency becomes genuinely variable across the client bank, the servicing model behind it needs to flex with it too, not just the calendar.
• Check that the service agreement, client communications and charging structure still accurately describe what the client will receive.

That last point is one we spend a lot of time on with firms, if I’m honest. It’s rarely the review itself that’s the hard part. It’s building a servicing model, and a fee structure, flexible enough to support reviews that don’t all happen on the same twelve-month clock, without the whole operation losing its shape.

The FCA moving away from a fixed annual requirement doesn’t remove the need for a review process. It just moves the hard part earlier, from running the review to deciding when one’s actually needed. Firms who’ve never had to make that call before are about to need a reason for one.

What’s your process today for deciding when a client is due a review, and where would that reasoning live if someone asked to see it?

If you’d like to learn more about how we support financial planning firms with suitability consulting, annual reviews and operational support, you’ll find more information here:

Suitability Report Writing Services for Financial Advisers

A paraplanner I work with sent me a message a few weeks ago that just said, “have you seen CP26/10 yet?” I hadn’t, not properly. I’d seen it mentioned in passing and filed it under things @Paul and the team would probably be all over. By the end of that conversation, I understood why she’d flagged it.

CP26/10: Simplifying the pensions and investment advice rules

The FCA is proposing to change part of the wording underpinning suitability assessments. Right now, firms have to gather the information “necessary” to assess suitability. Under the new proposal, that becomes information that’s “sufficient” to reasonably demonstrate a recommendation is suitable.

Two words. Both sound perfectly reasonable on their own.

But swap one for the other and the question the file has to answer shifts. “Necessary” can easily be interpreted defensively, with firms gathering everything they might conceivably need. “Sufficient” appears to give more room for proportionality, but it also introduces a judgement firms will need to apply consistently: have we gathered enough, for this client, in this situation, to justify the recommendation we’ve made? That’s a harder question, and a much more interesting one.

Why this isn’t really a compliance question

I know you’ve heard me say this a few times before: I’m not a paraplanner, and I wouldn’t try to explain COBS 9 to anyone who actually writes suitability reports for a living. But I speak to a lot of people who do, along with advisers, business owners and heads of paraplanning, most days of the week, and the same concern keeps surfacing in slightly different words.

If “sufficient” becomes the standard, who decides what’s sufficient for a particular client? Is it the adviser, using years of experience to judge in the moment? Is it a template, built once and used for everyone regardless of the case in front of them? Is it whoever happens to be writing the report that day, using their own sense of what good enough looks like?

Because if the answer is all three, depending on who’s involved, a firm doesn’t really have one suitability standard. It has as many standards as it has people writing reports.

What we’d suggest doing now

The Policy Statement isn’t expected until Q4, so there’s no need to panic. But a few of the firms we work with have already started having this conversation internally, and a handful of things have come up as genuinely useful starting points:

• Read the actual wording on “sufficient” in the consultation paper itself, not just a summary of it. It’s short, and worth reading in full rather than relying on someone else’s interpretation.
• Pull a handful of recent files and ask honestly: would we be comfortable calling this file “sufficient” if we had to justify it, rather than “necessary” because we ticked the boxes on a template?
• Decide, as a team, who owns that judgement call, not file by file, but as a process for setting the standard everyone works to.

• Build in time to revisit this once the Policy Statement is actually published. Near-final proposals have a habit of shifting slightly at the last hurdle, and this one touches the language behind almost every recommendation a firm makes.

None of that needs to happen overnight. But a file standard that’s decided by habit rather than by design is exactly the kind of thing that gets harder to unpick the longer it’s left.

Where we fit into that conversation

This is genuinely the kind of conversation we end up having with firms anyway, usually not because anyone’s asked us to interpret the rules, but because we’re looking at the same files week in, week out, across different advisers and different cases. Consistency is often easier to spot from the outside than from inside a single desk.

We’d love to hear how you think “sufficient” will play out in practice for your files, and whether your firm has already started defining what that looks like.

If you’d like to learn more about how we support financial planning firms with suitability consulting, annual reviews and operational support, you’ll find more information here:

Suitability Report Writing Services for Financial Advisers