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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

Since targeted support was confirmed, most of the discussion has focused on what it is and who can offer it. The conversations we’ve been having have been slightly different. They’re about what happens when a firm starts delivering targeted support alongside full regulated advice.

 

Two kinds of recommendation, one client bank

Targeted support isn’t full advice. It doesn’t need the same personal recommendation, and it doesn’t need a suitability report in the way COBS 9.4 requires for regulated advice. That’s rather the point of it, since it’s meant to be lighter touch, quicker to deliver, and available to people who wouldn’t otherwise get anything at all.

But most firms offering it won’t be running two separate businesses side by side. They’ll be running one client bank, where some clients get targeted support, some get full advice, and some get both at different points as their circumstances change.

That’s where it gets interesting from a file perspective, because the client doesn’t experience these as two different regulatory categories with two different standards behind them. As far as they’re concerned, their adviser told them to do something.

 

Where this could go wrong

The most likely failure probably isn’t a firm getting targeted support badly wrong for one particular client. It’s more likely to be a firm building it as a genuinely separate process, run by a different part of the business, with its own assumptions, its own records and its own owner, sitting alongside full advice rather than connected to it.

Six months in, nobody would necessarily notice. A year in, a file review or a client complaint might be what surfaces a case where the segment-level assumption and the client’s actual circumstances had drifted apart somewhere along the way.

That’s not really a targeted support problem specifically. It’s the same lesson firms have already learned from running annual reviews, onboarding and servicing slightly differently across a growing business. Consistency has to be designed in. It rarely happens by accident.

 

The consistency question

If targeted support is built around “people like you” assumptions, and full advice is built around one client’s actual circumstances, a firm needs to be confident the two aren’t pulling in different directions without anyone noticing. A few questions we’ve found useful when working through this with firms:

Would this client have received the same underlying message through full advice?

If targeted support nudges someone toward moving cash into investments, and a full suitability process for a similar client would have paused on capacity for loss, that’s worth catching before it becomes a pattern across the client bank, not afterwards.

Who is checking the assumptions behind the segment, rather than just the individual outcome?

Full advice gets checked file by file. Targeted support, by design, gets checked at the level of the segment and the assumptions sitting behind it, and that calls for a different kind of oversight rather than a lighter version of the one already in place.

What happens at the handover point?

If a client moves from targeted support into full advice, or the other way round, is there a clear record of what they were told, when, and on what basis? That record matters just as much as the suitability report itself.

 

What firms may want to evidence

For firms offering targeted support, or building toward it, a lot of the groundwork looks less like new advice process and more like new governance sitting behind it. That might include evidencing:

•     How a client is identified as belonging to a given segment, and on what data.

•     What assumptions sit behind the segment, and who signed them off.

•     How often those assumptions get reviewed, given they’re being applied to many clients rather than tested against one.

•     What a client is actually told, and how that record is kept, given there’s no suitability report to fall back on.

•     How a firm would spot targeted support and full advice pulling clients in different directions.

•     What happens if a client acts on targeted support and it turns out to be the wrong call for their specific circumstances.

•     Who owns the decision to move a client from targeted support into full advice, and when that trigger should be pulled.

None of that is about slowing targeted support down. It’s about giving the lighter-touch process the same discipline firms have spent years building into suitability files, just applied in a different way.

 

The question I keep coming back to

Targeted support is meant to help more people get useful support, and that’s a genuinely good thing for an industry that has spent years talking about the advice gap. But good intentions and good file evidencing are two different things.

For me, the real work over the next year isn’t building the targeted support proposition itself. It’s the quieter work of making sure it doesn’t drift away from what full advice is telling other clients, and that somebody in the business actually owns keeping the two aligned.

Targeted support is designed to close the advice gap. The firms that deliver it successfully won’t just be the ones that build a proposition. They’ll be the ones that build the governance around it.

Has your firm started thinking through how targeted support will sit alongside full advice, and who owns making sure the two stay consistent?

Further Reading

If you missed the first two editions of Behind Better Advice, you can read them here.

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.

When an advice firm starts to feel stretched, the obvious answer is often:

“We need another paraplanner.”

And sometimes, that’s exactly the right decision.

But before you start writing the job description, I think there’s one question worth asking…

What problem are we actually trying to solve?

Because needing more support doesn’t always mean needing another permanent employee.

Recruitment is a big investment. Not just financially, but in the time it takes to advertise, interview, wait out a notice period, onboard someone and help them get up to speed.

We know that first-hand. We’ve been recruiting ourselves recently, and finding experienced paraplanners isn’t always quick or straightforward. Even when you find the right person, there’s still a notice period to work through and time spent helping them settle into the business.

That’s not a reason not to recruit.

It’s simply a reminder that recruitment solves one problem, but it isn’t the answer to every problem.

 

Is it really a capacity issue?

Perhaps the business has grown and there genuinely aren’t enough hours in the day.

If that’s the case, recruiting may well be the right decision.

But sometimes the pressure is temporary.

It might be tax year end.

It might be a maternity leave.

It might be someone handing in their notice.

It might be an unexpected increase in new business.

Or it might simply be that the team needs a bit of breathing space while recruitment is underway.

They’re all slightly different situations, and they don’t necessarily need the same solution.

 

Or is something else causing the pressure?

Sometimes a team feels overloaded because the workload has increased.

Sometimes it’s because the process around the work has become inefficient.

Cases bounce backwards and forwards because something is missing.

Reports sit waiting for approval.

Advisers spend time chasing updates.

Paraplanners end up doing work that could sit elsewhere in the process.

Adding another person might ease the pressure.

But it might not solve what’s creating it.

 

Do you need another person, or different capability?

One of the things I’ve noticed over the past couple of years is that the support advice firms need has become much broader.

It isn’t always about writing another suitability report.

Sometimes it’s an experienced technical sounding board.

Sometimes it’s implementation support.

Sometimes it’s help with annual reviews.

Sometimes it’s improving workflows.

Sometimes it’s simply having extra capacity available when things get busy.

They’re all different challenges, but it’s easy to bundle them together under one sentence:

“We need another paraplanner.”

 

It doesn’t have to be in-house or outsourced

I think this is where the conversation is changing.

The firms we work with aren’t choosing between an in-house team and outsourced support.

Many have both.

They recruit because they want to invest in their business long term.

They bring in external support because they need flexibility, specialist experience or extra capacity while they continue to grow.

One doesn’t replace the other.

Often, they complement each other.

For me, that’s probably the biggest shift I’ve seen over the last few years.

Outsourcing isn’t just about filling a gap anymore.

It’s about giving firms access to capability exactly when they need it.

If your firm suddenly became 30% busier tomorrow, what would your first instinct be?

Would you recruit?

Would you improve your processes?

Or would you bring in some external support while you worked out the best long-term solution?

I’d be genuinely interested to hear how other firms approach it.

For firms weighing up their options, it can help to look at the wider picture rather than treating recruitment as the only answer. That might mean bringing in outsourced paraplanning support for extra capacity, reviewing where process improvements could remove pressure, or using external support for areas such as annual planning reviews while the in-house team focuses on the work that needs their attention most. The right solution will be different for every firm, but having more than one option usually makes it easier to respond without rushing into the wrong decision.

Over the past few weeks, I’ve noticed a real shift in the conversations happening around AI.

Not that long ago, people were asking what it might be able to do.

Now they’re talking about what it’s already doing.

People are comparing different tools, sharing how much time they’ve saved and swapping ideas on everything from meeting notes and task creation to document generation and form filling.

I found myself reading one of those discussions this week and it really got me thinking.

Interestingly, nobody was talking about replacing advisers.

Or technical judgement.

Or suitability.

Instead, they were talking about saving time.

That felt significant.

Because maybe we’ve been asking the wrong question.

Rather than asking whether AI can produce a document, perhaps we should be asking what becomes more valuable once producing the document takes less time.

That thought stayed with me throughout the week, particularly because of the conversations I was having with advice firms.

One firm got in touch on a Friday. We met on the Monday, agreed everything by Wednesday, completed the onboarding on Thursday and had them ready to send work by Friday. They needed support quickly, but they also wanted a provider willing to fit around the way they already worked, rather than asking them to adopt someone else’s templates and processes.

Another firm wasn’t in a hurry at all. They wanted another conversation, more technical information and time to complete their own due diligence before making a decision.

One of our existing clients asked what the maximum level of support we could provide over the next six months would be as their business continues to grow.

Another firm asked whether, once we’d completed the suitability report, we could also take ownership of implementing the advice across every case we worked on.

And one conversation stood out more than any other.

The firm already had an in-house team.

They weren’t looking to replace it.

They wanted experienced technical support around a less experienced team. People they could bounce ideas off, challenge difficult cases with and help develop confidence over time.

When I looked back over the week, something became obvious.

None of those conversations were really about report writing.

They were about confidence.

Ownership.

Consistency.

Experience.

They were about knowing there was someone there when capacity suddenly changed, when a complex case landed on the desk, or when another perspective would help strengthen a recommendation.

That feels like quite a significant shift.

For years, much of the conversation around outsourced support has centred on producing suitability reports.

Can you write the report?

How quickly can you turn it around?

How much does it cost?

Those questions still matter.

But increasingly, I’m hearing different ones.

Can you support our team?

Can you help us improve consistency?

Can you take ownership of implementation?

Can you strengthen our processes?

Can you adapt to the way our business already works?

They’re very different conversations.

And I don’t think many people would argue that technology is going to take more of the repetitive work off our desks over the next few years.

Personally, I think that’s a positive thing.

If technology can reduce the time spent formatting documents, moving information between systems or producing a first draft, it gives us more time to focus on the things that genuinely improve advice.

Technical judgement.

Critical thinking.

Supporting advisers.

Developing less experienced team members.

Improving operational consistency.

Strengthening the evidence behind recommendations.

Maybe that’s where the real value has always been.

For me, the more interesting question isn’t whether technology can produce a document.

It’s whether it can help firms produce better, more consistent advice.

Can it identify missing information before a case progresses?

Can it highlight inconsistencies that might otherwise be missed?

Can it strengthen the evidence behind a recommendation?

Can it give firms greater oversight across every case, rather than just the ones selected for review?

Those feel like much more valuable questions.

And I suspect they’re the conversations we’ll be having far more often over the next few years.

Technology will continue to evolve.

So will the way we all work.

But I don’t believe the future is about replacing people.

I think it’s about giving experienced professionals more time to do the things technology can’t.

To challenge.

To question.

To coach.

To improve.

And ultimately, to help firms deliver better advice.

I’d be really interested to hear your thoughts.

Has technology changed what you expect from suitability support, or has it simply changed where you think the real value now sits?

Further Reading

If you missed the first edition of Behind Better Advice, you can read it here:

Behind Better Advice

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

Why does every advice firm seem to have a different annual review process?

One of the things I enjoy most about my role is seeing how different advice firms operate behind the scenes.

Over the years, we’ve worked with firms of all shapes and sizes. Some have dedicated paraplanning teams. Some have one adviser doing almost everything. Others sit somewhere in the middle.

Recently, I came across a discussion between advisers that asked what sounded like a simple question:

“How do you collect client information before an annual review?”

The replies were fascinating.

Some firms send digital fact finds. Others rely on client portals. Some still post paper forms. Quite a few said they’d stopped asking clients to complete anything beforehand and simply update everything during the meeting instead.

There wasn’t a right answer.

There wasn’t even a common answer.

Everyone had developed a process that worked for their business, their clients and their team.

It made me realise something.

Perhaps the challenge isn’t finding the perfect annual review process.

Perhaps it’s recognising that every advice business is trying to solve a slightly different problem.

Annual reviews aren’t the difficult part

When people talk about annual reviews, they often picture the meeting itself or the suitability report that follows.

In reality, they’re only a small part of the overall process.

Long before an adviser sits down with a client, somebody has contacted them, arranged the meeting, gathered information, updated records, requested valuations and made sure everything is ready.

After the meeting, the work continues.

Recommendations need implementing.

Providers need chasing.

Platforms need updating.

Suitability reports need preparing.

Actions need recording.

Then, while all of that is happening, the day-to-day servicing doesn’t stop.

Client emails still arrive.

Withdrawal requests still need processing.

Addresses change.

Direct debits need amending.

New clients need onboarding.

It isn’t one task that consumes time.

It’s the accumulation of hundreds of smaller ones.

Why every firm looks different

Reading through that discussion, one thing became obvious.

The technology wasn’t really the issue.

Some firms had excellent systems.

Others preferred simpler processes.

Some had embraced automation.

Others deliberately hadn’t.

The common challenge wasn’t software.

It was people.

Clients don’t always complete forms.

Sometimes they don’t understand what’s being asked.

Sometimes they forget.

Sometimes they only remember something important once they’re sitting in front of their adviser.

That’s why there probably isn’t a single “best” annual review process.

Good firms build one that works for their clients, not somebody else’s.

What we’ve learnt

One of the biggest lessons we’ve learnt from working alongside advice firms is that structure matters far more than standardisation.

No two firms operate in exactly the same way.

Some want support preparing annual reviews.

Others want help managing implementation.

Some need somebody to own provider chasing and back-office updates.

Others are looking for support with onboarding, workflow design or simply making better use of their CRM.

Trying to force every business into the same process rarely works.

The best servicing models are built around the business, not the other way round.

Behind Better Advice

Over the coming months, I’ll be sharing a series called Behind Better Advice.

Each edition will look at a real project we’ve worked on (anonymised where appropriate), the operational challenge behind it and the practical lessons we learnt along the way.

Next week we’ll be publishing the first downloadable case study.

It follows a Paradigm member firm that wanted to strengthen the structure behind its annual reviews and ongoing client servicing. Rather than creating a completely new process, we worked together to build a servicing model around the way the business already operated.

I hope it’ll be useful for firms reviewing their own servicing models, whether they’re looking to make small improvements or thinking more broadly about how work flows through the business.

In the meantime, I’d love to hear your thoughts.

If you were designing your annual review process from scratch today, what would you do differently?

Further Reading

If this has got you thinking about how your own annual review process is structured, you can find out more about how we support firms with suitability consulting, annual reviews and ongoing client servicing here:

🔗 Suitability Consulting Support

Next week, we’ll also be publishing the first Behind Better Advice case study, Building a Bespoke Client Servicing Model.

It takes a closer look at how we worked with a Paradigm member firm to design a servicing model around the way they already operated, covering everything from annual reviews and implementation through to workflow design and ongoing client servicing.

I hope you’ll find it useful.

Just some Friday musings from me Amy North

Over the last few weeks, we’ve been recruiting at We Complement.

If you’ve been following us on LinkedIn, you’ll probably have seen a few of the posts.

What you probably haven’t seen is the number of conversations we’ve had behind the scenes.

And honestly, they’ve been one of my favourite parts of the whole process.

We’re not really formal interview people.

Of course, we need to understand someone’s experience and whether they can do the role, but if you’ve had a chat with me and Paul Kenworthy over the last few weeks, you’ll know I’m far more interested in hearing your story.

How did you end up in financial services?

How did you find your way into this profession?

What do you enjoy most?

What would you change if you could?

I’ve probably spent more time talking about careers, children, hobbies and life than I have asking interview questions.

One thing kept coming up.

Hardly anybody actually planned to end up here.

Almost everyone just… found it.

That made me smile because when I thought about our own team, exactly the same thing had happened.

Lucy originally studied Film and TV Production. She imagined a completely different career before deciding she wanted the stability of a regular office job. Today, one of her favourite parts of the role is writing suitability reports because it lets her combine technical research with something she’s always loved, writing.

Claire started out in pension administration before gradually moving into a more technical role. She talks about enjoying “putting the puzzle pieces together” to build a solution for clients, which perfectly sums up the way she approaches every case.

Hannah? She’ll quite happily admit she only ended up in financial services because a recruiter found her CV. Now she gets genuine satisfaction from taking one of those files where you wonder where on earth to start and turning it into something clear, well-structured and meaningful for the client.

Different backgrounds.

Different journeys.

The same profession.

One thing I loved was that no two stories were the same.

Some started in pensions.

Some came through administration.

Some had worked in compliance.

One had studied Film and TV.

Nobody followed the same path.

Yet somehow they all ended up in the same profession.

The people we’ve spoken to over the last few weeks were no different.

One person had been freelancing exclusively for the same adviser for years.

The relationship worked brilliantly, but she’d reached a point where she wanted the security that comes with being employed. Her adviser simply didn’t want the responsibility and overheads that come with taking on staff.

It reminded me that flexibility looks different depending on where you are in life.

Then we met two brilliant people who’d done the complete opposite.

They’d taken the leap and started their own businesses.

I absolutely loved hearing about it.

It takes confidence to back yourself like that, and I genuinely think it’s brilliant that more people now see that as an option.

They weren’t looking to leave because things weren’t working. They just wanted a little part-time work while they built their client base.

Unfortunately, we couldn’t make that work, which was genuinely disappointing because they really knew their onions.

Then there were the working parents.

The conversations weren’t about salary.

They were about school runs.

Sports days.

School plays.

The inevitable phone call from school because someone’s been sick.

Being able to disappear for an hour in the afternoon without feeling guilty, then picking work back up later that evening.

As a mum of three myself, those conversations really resonated.

What struck me most about all these chats was that very few people were simply chasing a bigger salary.

Some wanted the security that comes with being employed.

Others wanted more flexibility around family life.

A few wanted the freedom to build something of their own.

And quite a few wanted to work somewhere that genuinely values good technical thinking, where they could ask questions, challenge ideas and be part of the advice process rather than simply writing reports at the end.

That last one came up more than once.

It made me realise how much our profession has changed.

When I first came across it, it was often talked about as a stepping stone to becoming an adviser.

I don’t hear that nearly as much anymore.

People are choosing technical careers in financial planning because they genuinely enjoy the work.

They like solving problems.

They enjoy researching.

They take pride in explaining complex recommendations in a way clients can actually understand.

They’re proud of what they do.

And they should be.

Something else I noticed was just how supportive this profession is.

Every single person we spoke to was happy to share their journey.

Some talked openly about mistakes they’d made.

Others shared advice they’d been given early in their careers.

Nobody felt competitive.

Everyone seemed genuinely happy to help the next person coming through.

I think that’s pretty special.

I can’t think of many careers where so many people seem to have found themselves doing something they never planned… and then couldn’t imagine doing anything else.

The last few weeks have reminded me that our profession is in a really good place.

People are backing themselves.

They’re building careers, businesses and lives that work for them.

They’re choosing workplaces that value good thinking, not just quick turnaround times.

And if that’s the direction we’re heading, I think we’re all onto something pretty special.

There is a point in some tax-efficient investment cases where the conversation can start to sound very tidy.

The client has an inheritance tax concern.

Or an income tax liability.

Or a gain they want to manage.

Or they have used other allowances and want to know what else could be considered.

And before long, Business Relief, EIS, AIM portfolios or VCTs are part of the discussion.

That does not mean they are wrong.

Far from it.

For the right client, in the right circumstances, these can be valuable planning tools.

But they are rarely simple advice cases.

And that is where the suitability conversation needs to slow down a little.

 

The relief is not the whole recommendation

Tax relief is often the reason the conversation starts.

It is usually the bit the client understands first.

It can feel tangible.

It can feel attractive.

It can feel like the “why” behind the recommendation.

But it cannot do all the heavy lifting.

Because underneath the relief, there are still some fairly big advice questions.

Can the client afford the risk?

Do they understand the liquidity position?

Is the holding period realistic?

Do they understand what smaller-company exposure really means?

Could they cope if the investment falls in value?

Have simpler planning options been considered first?

And probably one of the most useful questions:

Would this still feel suitable if the tax relief was not there?

Not because the tax relief is irrelevant.

It clearly matters.

But if the recommendation only works when the tax benefit is doing most of the talking, it probably needs more challenge.

 

Different products, similar suitability themes

Business Relief, EIS, AIM portfolios and VCTs all do different jobs.

They have different rules, different planning uses, different risks and different client outcomes.

But when you look at the suitability work behind them, a lot of the same themes keep coming up.

Risk.

Liquidity.

Client understanding.

Capacity for loss.

Time horizon.

Charges.

Investment experience.

The client’s wider plan.

And whether the recommendation is proportionate to the objective.

That last one matters.

Because it is very easy for a tax-efficient investment to look sensible in isolation.

The harder question is whether it makes sense for this client, at this point, for this objective, with this level of risk.

Here’s a simple way to look at the main suitability focus, key risks and evidence points across four common tax-efficient investment areas.

It is not a replacement for full research or advice, but it can be a useful sense-check before the recommendation becomes too focused on the relief.

The report needs to explain the trade-off

A good suitability report should not just explain how the tax relief works.

It should explain the trade-off.

What is the client hoping to achieve?

Why is this route being considered?

What alternatives have been discounted?

What are the main risks?

How has capacity for loss been evidenced?

What does the client understand about access, holding period and potential loss?

How does this investment fit alongside the rest of the client’s planning?

That is where the advice becomes more defensible.

Not because every sentence needs to sound technical.

But because the reasoning is clear.

A reviewer should be able to follow the logic without having to guess why the recommendation was made.

And the client should be able to understand what they are accepting, not just what they might save.

 

A practical sense-check for advisers

Before finalising a tax-efficient investment recommendation, it can help to step back and ask:

1. What is the real planning objective?

Is this about inheritance tax planning, income tax relief, CGT deferral, tax-efficient income, portfolio planning, or something else?

And is that objective clearly evidenced in the file?

2. Is the recommendation proportionate?

Does the level of risk, complexity and illiquidity make sense compared with the client’s need?

Or is the tax benefit pulling the case further than it should?

3. What risks need to be explained clearly?

Not just listed.

Explained.

Capital risk.

Liquidity risk.

Qualifying risk.

Smaller-company exposure.

Exit risk.

Holding period.

Income uncertainty.

The client needs to understand the trade-off in plain English.

4. What would make this case hard to defend later?

This is a useful one.

If the file was reviewed in two years, what would someone question?

The client’s capacity for loss?

Their investment experience?

The size of the recommendation?

The reason simpler options were discounted?

The explanation of liquidity?

Those are often the areas worth tightening before the report is finalised.

 

Where the real work sits

A lot of the work behind good advice happens before the client ever sees the final report.

The research.

The challenge.

The provider and product checks.

The awkward questions.

The gaps that need filling.

The “hang on, does this actually fit?” bit.

It is not always the most visible part of the advice process.

But it is often the part that makes the recommendation stronger.

And with Business Relief, EIS, AIM portfolios and VCTs, that work really matters.

Because these recommendations need more than a tax explanation.

They need evidence that the client understands the risks, accepts the trade-off and is suitable for the route being recommended.

We have pulled together a practical guide

At We Complement, we have created a guide called:

Tax Relief Isn’t the Whole Story

It covers Business Relief, EIS, AIM portfolios and VCTs from a suitability angle.

It is not designed to be a technical tax manual or a product guide.

It is more of a practical support piece for advisers, paraplanners and suitability teams who want to sense-check the questions behind these recommendations.

Inside, we look at:

• the main suitability considerations across BR, EIS, AIM portfolios and VCTs
• the risks that need to be explained clearly
• the evidence that should sit behind the recommendation
• client understanding and capacity for loss
• how to stop the tax relief becoming the whole story
• practical questions to ask before the report is finalised

Because tax relief can open the conversation.

But suitability has to carry it.

If you would like a copy of the guide, give us a shout and we will send it over.

Useful external links

For advisers who want to check the underlying rules and guidance, these are useful places to start:

Business Relief for Inheritance Tax

 

Enterprise Investment Scheme (EIS) and Venture Capital Trusts (VCT) changes

 

COBS 9 Suitability (including basic advice) (other than MiFID and insurance-based investment products)

 

Consumer Duty

 

These links do not replace provider due diligence, tax advice or firm-specific compliance guidance, but they are useful reference points when sense-checking the advice file.