Advice firm readiness check: ten yes-or-no questions on ongoing service, suitability files, client data and record keeping

This check is for the owner, adviser or practice manager of a small FCA-regulated advice firm or mortgage broker. The ten questions cover ongoing service evidence, clients who do not reply, suitability reports, the Consumer Duty report, AI and client data, meeting recordings, chasing providers and how long files are kept, each taken from a rule or practice set out in our guides. The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and this page is general information, not regulatory or financial advice.

There are ten questions and they take about five minutes. Answer from memory. "Not sure" counts as a gap, because a rule nobody in the office can recall is a rule nobody is checking.

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Advice firm readiness check: ten yes-or-no questions on ongoing service, suitability files, client data and record keeping

1. For every year a client has paid an ongoing charge since 2018, could you put your hand on a dated invitation, a questionnaire or valuation, and a dated meeting or written review?ChooseYesNoNot sure
2. Have you reworded any client agreement from an annual to a periodic review because of CP26/10?ChooseYesNoNot sure
3. Is any client still paying an ongoing charge after ignoring review invitations two years running, with no recorded decision about the fee?ChooseYesNoNot sure
4. Does every suitability report you send state the client's demands and needs, why the recommendation is suitable for them, and any possible disadvantages?ChooseYesNoNot sure
5. Has your governing body reviewed and approved a Consumer Duty report on outcomes monitoring within the last twelve months?ChooseYesNoNot sure
6. Does anyone in the firm paste client information into an AI chatbot from a personal login?ChooseYesNoNot sure
7. Before a client meeting is recorded, is the client told, and could you give them a copy of the record if they asked four years later?ChooseYesNoNot sure
8. Is any letter of authority more than 20 working days old still being chased by another email, with no escalation?ChooseYesNoNot sure
9. Could any pension transfer advice file be deleted by a clear-out, an auto-delete rule or a change of back-office system?ChooseYesNoNot sure
10. Do you have a list of the clients who need a conversation about pensions and inheritance tax before 6 April 2027?ChooseYesNoNot sure

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What each question checks

1. For every year a client has paid an ongoing charge since 2018, could you put your hand on a dated invitation, a questionnaire or valuation, and a dated meeting or written review? The answer that is in order is "yes". The FCA's review of 24 February 2025 found promised reviews delivered in 83% of cases and asked firms to look back to 2018. A year counts as delivered only with all three items dated on file. Source: FCA, ongoing financial advice services review, 24 February 2025. The working is in The FCA's ongoing advice review, and the evidence pack a small firm needs for every client since 2018.

2. Have you reworded any client agreement from an annual to a periodic review because of CP26/10? The answer that is in order is "no". CP26/10 is a consultation that closed on 22 May 2026, with no policy statement by 1 October 2026. COBS 9A.3.9R still requires a firm providing a periodic suitability assessment to review its recommendations at least annually. Source: FCA CP26/10, 25 March 2026; COBS 9A.3.9R. The working is in CP26/10 for small advice firms.

3. Is any client still paying an ongoing charge after ignoring review invitations two years running, with no recorded decision about the fee? The answer that is in order is "no". The FCA sets no cut-off, but its February 2025 review lists policies to stop collecting fees from clients who have not engaged as good practice, and says firms should discuss whether the service is still in the client's best interest. Source: FCA, ongoing financial advice services review, 24 February 2025; FCA CP26/10, paragraph 3.21. The working is in Client not responding to annual review invitations.

4. Does every suitability report you send state the client's demands and needs, why the recommendation is suitable for them, and any possible disadvantages? The answer that is in order is "yes". COBS 9.4.7R sets those three items as the minimum contents of a suitability report. A document missing any one of them is not a suitability report, whatever else it contains. Source: FCA Handbook COBS 9.4.7R. The working is in Suitability report file check.

5. Has your governing body reviewed and approved a Consumer Duty report on outcomes monitoring within the last twelve months? The answer that is in order is "yes". PRIN 2A.8.3 requires a report on the results of outcomes monitoring and the actions required, which the governing body reviews and approves at least annually. In a small firm that body may be two directors. Source: FCA Handbook PRIN 2A.8.3. The working is in The Consumer Duty annual board report for a small advice firm.

6. Does anyone in the firm paste client information into an AI chatbot from a personal login? The answer that is in order is "no". The first condition in our guide is a business account on commercial terms that exclude training on the firm's data and give the firm control of retention and deletion. In 2026 surveys 39% of advisers used general AI tools for drafting. Source: FE fundinfo adviser survey, 16 July 2026; FCA AI Update, April 2024. The working is in AI and client data in an advice firm.

7. Before a client meeting is recorded, is the client told, and could you give them a copy of the record if they asked four years later? The answer that is in order is "yes". SYSC 10A requires clients to be told before recording. SYSC 10A.1.14R requires records to be given to the client on request and kept for five years, or up to seven where the FCA asks. Source: FCA Handbook SYSC 10A.1.11R and 10A.1.14R. The working is in Recording client meetings with an AI note taker.

8. Is any letter of authority more than 20 working days old still being chased by another email, with no escalation? The answer that is in order is "no". Our chase rhythm is 10, 15 and 20 working days. From the third chase at 20 working days it becomes a complaint under the provider's own procedure, with the adviser told, and not a fourth email. Source: Our own chase rhythm, built from paraplanner forum accounts of provider turnaround. The working is in Letter of authority and document chase email template.

9. Could any pension transfer advice file be deleted by a clear-out, an auto-delete rule or a change of back-office system? The answer that is in order is "no". COBS 9.5.2R requires suitability records for a pension transfer, pension conversion, pension opt-out or FSAVC to be kept indefinitely. The minimum is five years for pensions and life policies and three years in any other case. Source: FCA Handbook COBS 9.5.2R. The working is in How long must a financial adviser keep client files? The FCA minimum for each type of record, and a retention schedule to copy.

10. Do you have a list of the clients who need a conversation about pensions and inheritance tax before 6 April 2027? The answer that is in order is "yes". From 6 April 2027 most unused pension funds and death benefits are included in the estate for inheritance tax, and personal representatives, not scheme administrators, report and pay the tax. The conversations have to be scheduled before then. Source: HM Treasury and HMRC, government response on inheritance tax on unused pension funds, 21 July 2025. The working is in Pensions in the estate from 6 April 2027.

How to use the result

The list under your score is a to-do list. Each line names the rule, where it comes from and the page that shows how to deal with it. Put a name and a date against each one. A gap that has an owner and a date is being handled; a gap that everyone knows about and nobody owns is how firms end up explaining themselves later.

Do the check again each quarter, and again whenever a rule in this sector changes. Give it to a second person in the office without showing them your answers. Where the two of you disagree, the procedure is not written down clearly enough, and that is worth knowing whichever of you is right.

A good score is not a certificate. The questions cover the points our guides cover, which are the ones that come up most often in a small firm; they are not every duty a firm has. The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and this page is general information, not regulatory or financial advice.

Overlyft sets up AI assistants for financial advisers and mortgage brokers: they prepare drafts for a person to approve. They do not make a firm compliant, and none of the ten answers depends on them.