If you’ve been scanning the regulatory horizon lately, you’d be forgiven for thinking it’s been a bit quiet. No big consultations. No sweeping policy rewrites. No dramatic U-turns.
But quiet months often matter the most.
Because when you put the recent FCA updates side by side, and layer in what we’re seeing from FOS decisions, a clear theme emerges. The regulator’s focus is narrowing. Less noise. More intent. And a growing expectation that firms can evidence good advice, not just talk about it.
Here’s what’s caught our eye this month, and why it’s worth paying attention.
Cash ISAs: a policy idea that says a lot
The government’s proposal to slash the cash ISA allowance has been widely reported, and just as widely criticised. The idea, in short, is to push savers out of cash and into investments to support long-term growth.
Professional Paraplanner covered it well here:
Government doubles down on plans to slash cash ISA allowance
Whether or not this policy ever lands, the direction of travel matters. There is a clear and ongoing frustration at a policy level about the UK’s love affair with cash, and the perceived drag this creates on both individual outcomes and the wider economy.
For advisers and paraplanners, this isn’t about reacting tactically. It’s about being ready for the conversation.
Clients holding large cash balances often aren’t being irrational. They’re responding to uncertainty, poor past experiences, or a lack of confidence in markets. If policy pressure ramps up, those client conversations will become more frequent, and potentially more charged.
The takeaway here is simple. Firms that can clearly evidence why cash is appropriate, or not, for a given client will be far more comfortable navigating what comes next.
Mortgages, first-time buyers, and a widening advice gap
The FCA’s latest mortgage proposals focus on improving access for first-time buyers and the self-employed. Again, not headline grabbing, but quietly significant.
Professional Paraplanner’s summary is here:
FCA unveils mortgage plans to support first-time buyers and self-employed
What stands out is the regulator’s ongoing concern about people falling through the cracks. Those with non-standard incomes. Those priced out by rigid affordability models. Those who need advice the most, but struggle to access it.
This theme mirrors what we see elsewhere in regulation. The FCA is less interested in whether firms follow processes for their own sake, and more interested in whether outcomes make sense for real people with messy lives.
For advice firms, this reinforces the importance of joined-up thinking. Mortgage advice, protection, investments, pensions. They are not separate silos in the eyes of the client, or increasingly, the regulator.
“Millions to get more help” – and higher expectations with it
The FCA’s announcement that millions more people will receive help with investment and pension decisions sounds positive, and it is.
You can read the press release here:
Millions of people set to get extra help with investments and pensions decisions
But there’s a flip side.
More help means more scrutiny of how that help is delivered. Especially where guidance, support tools, and advice sit close together. The boundary issues haven’t gone away. If anything, they’ve become more important.
Firms offering streamlined services, annual reviews, or ongoing advice need to be crystal clear about what is being delivered, how often, and how it is evidenced.
Which brings us neatly to pensions.
Pension value under the spotlight
Another FCA release this month puts pension value firmly back on the agenda. Not just charges, but outcomes.
Pension value to be put under the spotlight
Value for money is no longer a vague concept. The expectation is moving towards demonstrable assessment. What is the client paying. What are they getting. And how do you know it remains appropriate.
Annual reviews play a central role here. Which makes recent FOS decisions particularly relevant.
A FOS reminder: if you can’t prove it, it didn’t happen
With regulatory updates thin on the ground, we’ve been keeping an eye on FOS decisions for practical insight. One recent case, DRN-5790176, is worth a read for anyone involved in arranging or documenting annual reviews.
In short, the client complained that they had not received the annual reviews they were paying for, and that their portfolio was unsuitable for a growth objective.
The adviser argued that reviews hadn’t taken place because the client was difficult to contact and had declined meetings. FOS accepted this might be true, but there was a fatal flaw. There was no evidence.
No emails. No call logs. No meeting invitations.
As far as FOS was concerned, if you can’t prove it, it didn’t happen. The outcome was a refund of ongoing advice charges, plus 8 percent simple interest per year.
Interestingly, other parts of the complaint were rejected. The adviser could evidence that attitude to risk had been revisited during reviews that did take place, and that portfolio composition had been clearly explained using review documentation and visuals.
Same client. Same firm. Different outcomes. All down to evidence.
What this all adds up to
Across policy proposals, FCA announcements, and FOS decisions, the message is consistent.
The regulator is less interested in intent, and far more interested in proof.
For firms, a few practical reflections are worth considering:
· Are annual reviews clearly defined, scheduled, and evidenced?
· Can you demonstrate attempts to engage clients, even when they disengage?
· Is your documentation good enough to stand alone, months or years later?
· Do your records tell the story without needing explanation?
These aren’t theoretical questions. They’re operational ones.
If this resonates with what you’re seeing in your firm, we’d love to hear from you. No pitch. Just people who spend a lot of time thinking about how advice stands up when it really matters.