Articles

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.

The Autumn Budget: What Next for Advisers?

The Autumn Budget has been announced for the 26th of November – the first time it has been held at the end of November since the mid-1990s. In the 12 weeks between now and the Budget, there is likely to be a lot of speculation surrounding the changes that might be made.

The Professional Paraplanner summary is a good starting point. Key points to flag:

• ISAs and pensions remain central –  speculation from AJ Bell that the government could combine Cash ISAs and Stocks and Shares ISAs into a single product. Changes to pension tax relief is an area that has been speculated about for some time, and it looks like this discussion is set to continue in the run up to the Autumn budget.

• Tax treatment remains in flux – further IHT changes are likely to be unwelcome after the recent changes to IHT. However, the government has backed itself into a corner slightly, having ruled out increasing income tax, NI and VAT. Something has to give. There has been talk of ‘stealth’ IHT tax increases (such as freezing IHT thresholds again), potentially a wealth tax, or changes to council tax.

• Policy continuity matters – with a budget on the horizon and speculation rife, clients may be more jittery about long-term planning, leading to “knee-jerk reactions based on rumours.”

The practical takeaway? Stay close to policy updates, and frame client conversations around resilience rather than chasing headline tax moves. The rules may shift, but the principles of building buffers, using allowances, and stress-testing plans don’t.

The Ongoing Puzzle of Tax-Free Lump Sums

One area where complexity persists is the treatment of tax-free lump sums under primary and enhanced protection. The Professional Paraplanner technical note is worth bookmarking.

Why it matters:

• The interaction between the lifetime allowance and the new rules can be a little complicated.  This helpful article takes you through the main technical points you need to know, as well as some helpful examples.

• Many clients assume 25% tax-free cash is always available. In fact, protections layered on pensions since 2006 create scenarios where entitlements vary.

• Primary and enhanced protection rules can mean higher tax-free entitlements than the standard allowance – but only if records are clear and the rules applied correctly.

• Advisers need robust evidence. With Consumer Duty now in force, you’ll need to show not just that the advice was technically correct, but that you’ve explained the position clearly to clients.

Our advice? Document assumptions carefully, and don’t rely on memory or firm lore. Each case needs a file note that could withstand FCA scrutiny if challenged later.

FCA Pushes for Simpler, Clearer Communication

The FCA is on a mission to make its own materials less of a maze. Two recent updates signal where things are heading:

• The new FCA Handbook site – easier to navigate, better search, and improved integration of sourcebooks.

• Simplified supervisory communications – moving towards clearer, plainer language when regulators engage with firms.

This isn’t just housekeeping. It sets an expectation. If the regulator is working to simplify how it talks, advisers and firms will be expected to do the same. Long, technical letters that bury the key message won’t cut it.

Practical tip: review your client letters and suitability reports. Could a non-specialist pick out the key points in 60 seconds? If not, it’s worth a rework.

Pension Transfer Lessons

The FCA’s multi-firm review of life insurers’ pension transfer processes highlights themes that apply across the industry. The FCA states the following:

• Ceding schemes made most transfer payments within a suitable time of receiving the request to transfer. More than three-quarters of the firms in their sample completed all transfer requests, on average, within 20 days.

• Five firms were responsible for over two-thirds of requests.

• About 87% of these transfers were processed by firms that told the FCA that they complete all transfers within 15 days.

• Where a transfer required no additional checks, the FCA found that over three-quarters of the firms completed these transfers within 10 days, with the shortest time being 5 day.

• ‘Amber flags’ indicating that a pension transfer needs extra checks were applied to less than 2% of transfer requests, most often caused by the receiving scheme including high-risk or unregulated investments; the receiving scheme’s charges being unclear or high; or overseas investments being included in the receiving scheme.

Does this align with your experience of dealing with pension switches?

Bringing It Together: What Advisers Can Do

If you only take three things from this roundup, make them these:

• Simplify your communication – assume every client and regulator wants the headline upfront.

• Evidence every decision – especially why options weren’t chosen. Assumptions without records are weak points.

• Prepare for real-time scrutiny – Consumer Duty and the FCA’s direction of travel mean advice needs to be audit-ready as it’s written, not weeks later.

The good news? None of this requires crystal ball gazing. It’s about process discipline, structured reasoning, and a culture of clarity. Firms that embed these habits now will not only stay compliant – they’ll stand out as trusted, modern advisers.

Final Word

At We Complement, we see the same patterns across firms: the best ones don’t wait for the regulator to nudge them. They tighten up their evidence, simplify their language, and make sure advisers feel supported rather than exposed.

If this resonates with what you’re seeing, we’d love to hear from you. Drop us a note or share how your firm is approaching these shifts – no pitch, just a conversation with people who get financial advice.

Robert Rubin once said: “Some people are more certain of everything than I am of anything.”It’s a reminder that in investing, the only certainty is uncertainty.

Two recent stories underline this. First, Novo Nordisk lost a fifth of its value in a single day after lowering its 2025 profit forecast. The company is still set to grow – just not at the sky-high levels investors had assumed. The result? Shares fell two-thirds from their peak, punishing anyone who believed growth would continue in a straight line.

Chart 1: Novo Nordisk’s sharp share price fall shows how quickly lofty forecasts can unravel.

Second, Deutsche Bank data shows only two of the ten largest companies in 2000 have outperformed the S&P 500 since then. Some now earn less than they did 24 years ago. Today’s “Magnificent Seven” may look unstoppable, but history suggests otherwise. Forecasts built on confidence often crumble under reality.

Chart 2: The top 10 stocks of 2000 underperformed the S&P 500 over the following two decades, a warning for todays market favourites.

So what does this have to do with bonds? Everything.

Bonds aren’t equities – and that’s the point

It’s tempting to apply the same logic to bonds that we use with equities: buy the index, avoid active managers, keep costs low. But fixed income is different.

• The Bloomberg Global Aggregate Index tracks over 31,000 securities across 72 countries.

• By comparison, the FTSE All-World Index covers around 4,200 equities.

Bond markets are vast, fragmented, and constantly evolving as new issues replace old ones. Companies issue one class of shares, but often dozens of bonds, each with different maturities, coupons, and structures.

That complexity creates inefficiencies – and inefficiencies create opportunity.

📖 For context, see the FCA’s overview of fixed income products and risks.

Why active fixed income still matters

In equities, active managers often struggle to beat the benchmark after fees. In bonds, the story can be different.

Active managers can:

• Unearth overlooked bonds that rarely trade but offer attractive risk-adjusted returns.

• Tilt towards improving economies, where sovereign yields are falling.

• Select issuers with strengthening fundamentals, where credit spreads may tighten.

They don’t need to forecast the future perfectly. They just need to use flexibility to reduce exposure where risk is rising, and increase exposure where markets misprice resilience.

Managing risk when forecasts fail

For clients, the bigger benefit isn’t just potential alpha – it’s risk management.

When expectations break down in equities, valuations can collapse overnight (as Novo Nordisk showed). In fixed income, active managers can adjust portfolios dynamically to smooth returns, protect capital, and keep portfolios aligned with client goals.

That agility supports:

• Capital preservation for clients worried about volatility.

• Income stability when yields are attractive but uneven.

• Outcome alignment, a key requirement under the FCA’s Consumer Duty PS22/9.

Passive vs. active – not either/or

None of this means passive bond funds don’t have a place. They remain a low-cost way to gain broad exposure. But framing the choice as “all passive” or “all active” is misleading.

The sweet spot may be benchmark-aware strategies: active funds that keep costs in check while using their flexibility to manage risk and exploit inefficiencies. Vanguard’s Global Core and Global Strategic Bond Funds are examples, designed either as standalone allocations or complements to index exposure.

What advisers and paraplanners should take away

For advisers, the key message for clients is simple: forecasts will fail. What matters is whether portfolios can flex when they do.

For paraplanners, this means documenting the rationale clearly:

• Diversification beyond the benchmark

• Risk management as well as return

• Alignment with client objectives, not just performance targets

That alignment is what makes suitability defensible – and what helps clients stay invested when forecasts inevitably disappoint.

The bottom line

Forecasting may be fragile, but strategy doesn’t have to be. Equity markets will always lure investors with stories of endless growth. History suggests those stories often end badly.

Bond markets, by contrast, offer scope to use complexity and inefficiency as tools for stability. Active fixed income isn’t about outguessing the market. It’s about building portfolios that remain resilient when the forecasts go wrong.

And if the last few months have shown us anything, it’s that forecasts willgo wrong.

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

Tax-Free Wealth Building in 2025: The Rise of Whisky Casks

A niche investment going mainstream

For years, whisky cask investment has been a quiet corner of alternative investing – something discussed more in collectors’ circles than in financial advice meetings. But 2025 is seeing a shift. Headlines talk about whisky casks as a tax-free wealth-building tool and investors are increasingly curious about whether this is a serious asset class or just another fad.

Cask Capital describes whisky casks as one of the “last tax-free investment opportunities in the UK,” highlighting both the capital gains tax exemptionand the growing global appetite for rare spirits. But as with any trend that promises outsized returns, financial advisers and paraplanners need to separate the marketing from the mechanics.

Why investors are drawn to casks

According to recent commentary:

• Tax treatment: Whisky casks are classified as a “wasting asset” in the UK. This means they typically escape Capital Gains Tax (CGT). That’s a powerful hook for clients searching for tax efficiency.

• Supply and demand: Whisky production is limited, maturation takes years, and global demand-particularly from Asia and North America-has never been stronger.

• Portfolio diversification: As an alternative investment, casks aren’t correlated with equities or bonds. They can add resilience in volatile markets.

It’s no wonder some investors now see whisky casks as a tangible, inflation-resistant store of value.

The practical risks

Of course, not all that glitters (or glows amber in a glass) is gold. A sober perspective is essential.

• Liquidity: Selling a cask isn’t like trading a share. The market is opaque, and exits can be slow.

• Valuation uncertainty: Cask value depends on age, distillery, and storage conditions. Transparent pricing data is limited, making it difficult to assess fair value.

• Fraud and mis-selling: Which? recently warned about firms overpromising or disguising fees in whisky investment schemes. This is a red flag advisers must highlight when clients show interest.

The FCA has also flagged concerns about niche, unregulated investments being sold without appropriate risk warnings. As with crypto a few years ago, consumer protection is the big question mark.

Choosing the right cask (if at all)

For clients who remain intrigued, there are some practical filters:

• Work with reputable brokers – Organisations like London Cask Traders and Cask Capital provide educational resources and (to an extent) pricing frameworks.

• Focus on established distilleries– Well-known Scottish distilleries with consistent brand value are less risky than newer entrants.

• Understand storage– Where and how the cask is matured affects both quality and value. Poor warehousing can erode returns.

• Plan the exit– Whisky isn’t just held; it’s sold. Advisers should stress the importance of understanding resale channels and timelines.

For advisers, the key is helping clients weigh the romance of owning a whisky cask against the practical realities of managing an illiquid, alternative asset.

What to tell clients

• Whisky cask investment candeliver attractive returns, but it’s not risk-free.

• Tax benefits are real but depend on HMRC continuing to classify casks as wasting assets. Policy changes could alter this.

• Due diligence is critical. If a client brings you a glossy brochure promising double-digit annual returns, approach it with the same scrutiny as any unregulated scheme.

Ultimately, advisers should frame whisky casks as a specialised, high-risk allocation-a potential addition for well-diversified, high-net-worth clients who understand the risks, but not a mainstream tax solution.

Our take

At We Complement, we don’t dismiss niche investments outright. They can spark valuable client conversations and open doors to deeper planning discussions. But our role-as paraplanners, advisers, and suitability consultants-is to stress test the logic, highlight the pitfalls, and make sure clients are making decisions with eyes wide open.

As the FCA’s Consumer Duty continues to sharpen expectations around evidencing good outcomes, it’s never been more important to document whyan investment is or isn’t appropriate. And whisky, for all its allure, demands that kind of clarity.

Final thought

Alternative investments like whisky casks will always attract attention, particularly in uncertain markets. The real test for advice firms is whether these ideas are handled with rigour and balance. Clients deserve both the excitement of opportunity and the discipline of good governance.

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

Ask most advice firms how they assure quality, and you’ll get a familiar answer: “We do QA checks after the file’s been submitted.” But here’s the rub. If your quality control only kicks in at the end, you’re not protecting your clients. You’re just crossing your fingers.

At We Complement, we believe the future of advice assurance isn’t reactive. It’s structured, evidentiary, and embedded from the start. And that’s where the Suitability Consultant comes in.

Why Traditional QA Isn’t Enough

Let’s be clear. Retrospective file checks still have a place. But they can’t carry the weight of regulatory expectation on their own. They’re too slow to prevent harm, too subjective to be consistent, and too backward-looking to drive change.

Retrospective QA creates what we call a “file repair culture.” Mistakes get patched, but root causes go unaddressed. That’s risky, especially under Consumer Duty, where firms must show how their advice actively delivers good outcomes, not just avoids harm after the fact.

Key rules like:

• COBS 9.2.1R (client suitability)
• SYSC 3.2.6R (risk systems and controls)
• PS22/9 (Consumer Duty)

…all require more than a tidy report. They demand a traceable advice logic that can stand up to internal scrutiny, external audit, and the FCA’s expectations for evidentiary discipline.

The Shift: Advice Built to Be Audited

Suitability Consultants operate differently.

Where a traditional paraplanner might build a report around adviser input, we start earlier in the process — testing the inputs themselves. Is the risk profile consistent with the objectives? Do the factfinding notes back up the recommendation? Are product choices driven by need, not preference?

Our process uses a structured toolkit:

• ARC (Advice Readiness Checks): Pre-advice triage that surfaces gaps in client context, factfinding, and risk profiling.
• ASL (Advice Suitability Logic): A 130+ rule framework to test alignment to FCA standards.
• SMS (Suitability Matrix Score): A logic-graded, versioned evidence report that supports both internal QA and external defence.

From QA to Proactive Precision

This isn’t about more process. It’s about smarter structure. When advice is built using embedded frameworks, QA becomes a formality. By the time the file lands in compliance’s hands, the logic is already documented, tested, and version-controlled.

Think of it this way:

• Traditional QA: “Does this advice meet the standard?”
• Suitability Consultant: “Let’s make sure the advice was built to the standard.”

That’s a big difference. It moves assurance upstream, where it can actually influence outcomes.

What This Means for Your Firm

If you’re still relying solely on end-stage checks, you may be exposing your firm to:

• Governance gaps — where override patterns go unnoticed
• Rework and delays — from back-and-forth file edits
• Audit risk — because logic can’t be clearly evidenced
• Inconsistent advice — when paraplanners have to “make it fit” post-fact

By embedding a Suitability Consultant model, you get:

✅ Advice logic aligned before submission

✅ FCA-mapped standards from start to finish

✅ Evidentiary assurance that supports SM&CR accountability

✅ Fewer escalations, faster delivery, and stronger client outcomes

Practical Tip: Test Your Own Files

Want a quick way to see if your process is fit for purpose? Pick three recent advice cases and ask:

1. Could someone with no context follow the logic from factfind to recommendation?
2. Are product choices justified in the client’s words, not just the firm’s preferences?
3. Would the file survive scrutiny without any “explainer” from the adviser?

If you answered “no” to any of those, don’t worry. It just means there’s room to evolve.

A New Standard Is Emerging

As regulation tightens and insurers demand more rigour, firms can’t afford to view QA as a final checkbox. The bar is rising. The ability to show how advice was constructed — step by step, standard by standard — is becoming a baseline expectation.

Suitability Consultants aren’t just helpful. They’re strategic infrastructure. And for firms who want to stay ahead, they may be the most valuable hire you’ve never made.

There’s a quiet but important shift happening across adviser tech, and if you blink, you might miss it. We’re not talking about a shiny new CRM or another data dashboard. We’re talking about what’s going on under the hood: integrations, partnerships, and AI pipelines that are shaping how advice gets built and delivered.

This month alone, we’ve seen:

• FNZ team up with Microsoft to explore AI-powered advice tooling
• Twenty7tec roll out a planning module with new CRM and cashflow integrations
• City AM select Third Financial as a new platform partner

That’s three signals in one month pointing to a bigger trend: the advice tech stack is maturing, and integrations are becoming non-negotiable. But what does that really mean for financial planners and paraplanners? And where does it leave firms trying to deliver good advice, not just good systems?

Let’s dig in.

From Tools to Ecosystems

We’ve all worked with ‘tech’ that made life harder, not easier. A platform login that doesn’t speak to the CRM. A client risk score stuck in a PDF. Rekeying data into suitability reports (again). It’s no surprise that some advice firms have been slow to adopt new tools—they’ve been burned before.

But the nature of tech is changing. What we’re seeing now isn’t just more tools, but better connectivity between them.

Take the Twenty7tec update as a prime example. Their new integration layer links to iPipeline, Genovo, Timeline, and more, bridging the gap between planning, risk, and suitability workflows. According to CEO James Tucker, “the focus is now on connecting, not just creating”.

This shift matters. Because disconnected tools don’t just slow teams down—they create advice risk. When data gets re-entered or misaligned between systems, the integrity of the advice narrative suffers. And under Consumer Duty, ‘close enough’ just isn’t enough.

Enter AI: Assistant or Risk?

Then there’s AI. The FNZ–Microsoft announcement highlights a growing appetite to embed large language models (LLMs) into advice tooling—think summarisation, pattern detection, and even recommendation support.

On paper, this sounds great. But here’s the catch: if AI is reading client files, assessing risk, or suggesting actions, the need for human oversight skyrockets.

As we often say: AI can enhance, but not excuse. You still need a clear, defensible logic path. You still need to evidence why a recommendation was made, not just what the tool produced. And unless that AI is aligned to current FCA rulesets, it’s not a shortcut—it’s a liability.

For now, AI is best seen as a co-pilot. A speed enhancer. A second set of eyes. But the judgment? That still sits squarely with the adviser, and ideally, a structured suitability consultant process.

What Firms Can Do Right Now

If you’re reviewing your own tech stack or planning for 2026, here are three practical questions to ask:

1. Are your systems talking to each other? Look at the points of friction: duplicate data entry, non-integrated risk tools, or manual report generation. These are not just time drains—they’re risk triggers.
2. Do your tools support your people? If automation is creating more rework or generating documents that need constant editing, it’s not really helping. The best tools simplify, not complicate.
3. Is your process auditable, not just operational? This is the big one. Under SYSC, COBS and Consumer Duty, you need more than a ‘completed’ advice file—you need to show the logic behind it, version it, and evidence that it aligns with client objectives and risk appetite.

If your QA team is still working at the end of the process, rather than alongside it, your tech is probably observational, not preventative.

Final Thought: It’s Not About the Tech. It’s About the Structure

At We Complement, we’re excited about tools like AMS (Advice Matrix Scoring), ARC (Advice Readiness Checks), and ASL (Advice Suitability Logic). But the point isn’t that we’ve got tech. It’s that we’ve built structure.

Every integration, every automation, every dashboard should serve a bigger purpose: helping firms deliver clearer, safer, and more consistent advice. If your tools aren’t doing that, it might be time for a rethink.

If any of this resonates with what you’re seeing in your firm, we’d love to hear from you. Whether you’re reviewing your tech stack, exploring AI, or just trying to smooth out your workflows, we’re always happy to chat. No pitch, just people who get it.

If the FCA’s July activity is anything to go by, the regulatory tide is gaining pace-and advisers need to be ready to swim with it, not against it.

This month’s roundup focuses on three things we think every financial planning firm should be across:

1. A significant shift in inheritance tax (IHT) liability on pensions
2. The FCA’s evolving position on AI and technology
3. A faster lane for firm authorisations-and what it signals

Let’s break them down.

🪦 IHT and Pensions: The Silent Risk for Personal Representatives

HMRC’s recent update could fly under the radar for many firms-but it shouldn’t.

From April 2027, personal representatives of estates will become liable for reporting and paying IHT on unused pension funds.

👉 The crux: pension scheme administrators are no longer expected to be liable for reporting and paying IHT on pensions. Instead, the burden of reporting and paying IHT will fall on the personal representatives.

This presents a new layer of complexity for those dealing with estates, especially in cases where:

• There are delays in processing or distributing pension funds

• The value of the pension is high and falls outside the scope of spousal exemption

• There’s poor clarity around nomination or expression of wishes

📌 Why it matters for advisers and paraplanners:

• Estate planning conversations now need to address the practicalitiesof pension death benefits, not just the theory.

• It’s worth reviewing how nomination forms and client expectations are discussed during annual reviews.

• Firms may want to flag this to professional connections (e.g., solicitors, accountants) to help ensure joined-up planning.

📖 Read the full FTAdviser article

🤖 FCA on AI: Promise, But with Caution Tape

At a recent speech hosted by Innovate Finance, the FCA’s Jessica Rusu outlined how the regulator views the rise of AI and large language models (LLMs) like ChatGPT.

What stood out was the tone: positive, but pragmatic.

The FCA recognises that AI has the potential to revolutionise:

• Advice delivery and suitability

• Client communications

• Back-office efficiency

But it also sees red flags if AI is deployed without proper controls.

🎯 Takeaways for firms:

• If you’re trialling or adopting AI tools, document the logic behind outputs.

• Make it clear who is responsible for sign-off.

• Ensure any client-facing outputs remain understandable to a non-specialist reader.

📖 Read the FCA’s full AI speech here

🏁 Speeding Up FCA Authorisations: A Welcome Signal

Finally, the FCA has announced a commitment to faster authorisation timeframes, with some decisions now expected in as little as 2 months.

This is more than a process tweak-it reflects a wider regulatory posture. The FCA is trying to:

• Support new entrants and innovation

• Streamline the bottleneck that’s historically slowed down firm launches

📌 Implications for existing firms:

• If you’re considering new permissions or structural changes, the window may now be less painful.

📖 FCA announcement on authorisation acceleration

👀 What This Signals: The Regulator is Moving Faster Than You Think

The common thread across all three updates?

Timeliness.

• Personal reps being liable? Linked to delays.

• AI’s promise? Must be matched by real-time explainability.

• Authorisations? Faster, but not lighter touch.

For compliance leads and operations managers, the takeaway is clear: regulatory expectation is shifting from checklists after the fact to structured control in the moment.

Whether it’s death benefit planning or AI adoption, firms must be able to show:

• Clear rationale

• Pre-emptive governance

• Evidence of oversight

Final Thought

None of this is about causing panic. But it is about being proactive-in your conversations, your processes, and your oversight.

We’re working with firms every day to help structure advice delivery in a way that stands up to this new pace of scrutiny.

Got questions? Just reach out – no pitch, just people who get financial advice.