Ongoing service review under Consumer Duty — agenda and file note for UK IFAs

You're a paraplanner. The annual review meeting is on Tuesday and the adviser sent the meeting calendar invite this morning with a single line in the description: "standard review, no major changes expected." You've been here before. You know "standard" means the adviser is going to walk in with the platform statement, talk about performance for forty minutes, ask if anything's changed, and leave you to write up something that demonstrates Consumer Duty has been considered. The agenda below is the work that turns that meeting from a chat into a defensible review.

Consumer Duty has hardened the ongoing-service bar materially. The "fair value" requirement under PRIN 2A.4 means the firm has to evidence, every year, that the fee charged for ongoing service maps to a service genuinely delivered. The FCA's Retail Investments Ongoing Advice Service Reviewwork made clear that taking an ongoing fee without a documented annual review is not survivable — and the regulator's view is that the review needs to be more than a portfolio valuation slide.

The seven-step agenda

1. Confirm circumstances have not changed materially

Open with the fact-find data on screen, item by item. Personal circumstances (marital status, dependents, employment, health), financial circumstances (income, expenditure, assets, liabilities), tax position, expressed wishes around estate planning. Walk through each line: still true, change to capture, or material change requiring further work.

The discipline of working from the prior fact-find means changes get noticed. Two-thirds of clients say "nothing's changed" and half of them are wrong; the line-by-line walkthrough catches the missed change.

2. Reconfirm objectives and priorities

Restate the objectives the advice has been working to since the last review. "We've been working to your objective of retiring at 62 with £42,000 of sustainable real income, with a secondary objective of leaving an inheritance to your children. Still right?" If the answer is no, capture the change. If the answer is yes, the file note records that the objectives were reconfirmed — which is itself an audit-relevant fact.

3. Reconfirm attitude to risk and capacity for loss

The risk-profiler doesn't always need to be re-run — if circumstances and objectives are unchanged, the prior ATR conclusion typically still holds. Capture the discussion that confirmed it. Where capacity for loss is materially affected by a change (income reduction, a large expenditure commitment, an inheritance) the capacity analysis has to be redone, with the stress test updated.

For clients in early-stage drawdown or clients flagged as potentially vulnerable, more cadence (six-monthly review) is the supervisory expectation.

4. Review the portfolio against segment design intent

The portfolio performance section. Not the part of the meeting where the adviser walks the client through fund-level returns — that's a conversation, not an audit artefact. The audit artefact is: how has the portfolio performed against the design intent of the CIP/CRP segment the client sits in? For an accumulator, has the growth been broadly in line with the segment's design? For a decumulator, is the sustainability of withdrawals still on track given the realised return path?

Where the answer is "yes, in line," the file note records it briefly. Where the answer is "no — material divergence," the file note records the analysis and the response: continue, rebalance, change of solution. The investment committee should be seeing this analysis aggregated across segments; the individual review records feed it.

5. Confirm vulnerability indicators

Run through the firm's vulnerability framework — the FCA's four drivers under FG21/1 (health, life events, resilience, capability). Capture any indicators that have appeared since the last review. Cognitive change, bereavement, change in care needs, change in capability to handle complex information. Where a vulnerability indicator is present, capture the resulting adjustment — communication style, document format, additional time, third-party involvement with consent.

This step is where Consumer Duty's support outcome bites. A review file note that doesn't address vulnerability — even to confirm no indicators were observed — is a gap that comes up in supervisory reviews.

6. Confirm fair value of the ongoing service

The hardest step to do honestly. The structure: the service the firm has actually delivered to this client over the period (annual review, interim contact, ad hoc query handling, document support, portfolio monitoring), the fee the client has paid for it, and the value framing.

The value framing isn't "we beat the benchmark." It's whether the ongoing relationship has produced outcomes the client wouldn't have produced on their own — tax efficiency that wouldn't have been captured, behavioural mistakes avoided, planning that adapted to a life event, sustainability monitoring on drawdown income. Where the value is hard to articulate, the firm has a question to ask itself about the fee structure rather than the file note.

The FCA's fair-value work explicitly contemplates that ongoing services are valuable. The expectation is that the firm can demonstrate the value rather than assume it.

7. Agree actions and the next review trigger

Anything arising from steps 1–6 that needs follow-up. The timeline for each action and the owner. The trigger for the next review — typically the next annual cycle, but with event-driven triggers documented (a major life event, a regulatory change affecting the client's position, a market event that pushes drawdown sustainability into the warning zone).

Closing the loop matters. A review that generates an action with no follow-up is worse than a review with no action, because it creates a documented obligation the firm then failed to meet.

The file note

One artefact per review. Held against the client record. The structure mirrors the seven-step agenda. Each section is a paragraph, not a sentence, capturing what was discussed, what was confirmed and what was agreed. Not a transcript and not a tickbox — somewhere in between. The test for the file note: could an independent reviewer, reading the note in three years' time, reconstruct the substance of the review meeting? If yes, the note is doing its job.

The note should reference (not restate) the supporting evidence: the updated fact-find, the risk-profile output, the portfolio analysis, the vulnerability assessment, the fair-value documentation. The supporting evidence lives in the client record; the file note references where to find each piece.

What the FCA is looking for in supervisory work

From the regulator's published Retail Investments Ongoing Advice Service Reviewoutput and from compliance consultants who've worked on s.166 reviews involving ongoing service:

• Reviews actually delivered for every client paying an ongoing fee — the most common finding in supervisory reviews is missing reviews, not poor-quality reviews
• File notes that demonstrate substance, not just attendance
• Vulnerability assessment embedded in the review process
• Fair-value evidence that engages with the actual service delivered rather than restating what's in the client agreement
• Evidence of action follow-through — actions identified in one review should be closed out in the next
• Frequency appropriate to circumstances — six-monthly for early drawdown and flagged vulnerability, annual otherwise, with event-driven triggers active

The workflow problem this solves

Most firms have the agenda above in some form — what they lack is the infrastructure to run it consistently across the client book. The annual review for client A is a thorough piece of work; for client B it's a portfolio valuation; for client C it didn't happen and the firm doesn't quite know that yet.

The fix is mechanical: a single client record that surfaces the review status, the prior fact-find, the segment, the portfolio against segment intent, the vulnerability flags and the fair-value evidence in one view; a workflow that prompts the seven-step agenda and captures the file note as a structured artefact. Wealth Analyticais designed for this — the ongoing-review workflow sits on top of the same source-of-truth client record that the recommendation came from.