The CCI Regime Makes You a Distributor. Here Is What That Obliges You to Do.
FCA PS25/20 defines a distributor as anyone who advises on a CCI. Advisers have three pre-sale minimums from 8 June 2027, and one date in December 2026.
Articles by Jonny Rowse
Suitability Reports Under Consumer Duty: COBS Says Say It, PRIN Says Be Understood
COBS 9A.3.2 says what a suitability report must contain. PRIN 2A.5.3 adds a test it never had: it must be likely to be understood.
When a DFM Client Dies: The Portfolio Is the Asset That Behaves Worst
Death hands the estate a free rebalance and takes away the authority to execute it. The three clocks that start on the date of death, and the protocol that should already exist.
Decumulation Portfolios: Why an Accumulation MPS Is Not Automatically Suitable
The FCA found 11% of retirement income advice files raised suitability concerns. The portfolio is often the part nobody reassessed when the client stopped contributing.
Eight Days: Running the Window from the 28 October Budget to the 5 November MPC
The Budget lands on 28 October and the MPC reports on 5 November. Eight days, two events, and one client communication window. How to run it without guessing.
The Real Cost of Discretionary Wealth Management: Evidencing Fair Value Across the Whole Stack
Most firms assess platform, DFM, fund and advice costs separately. Here is how to evidence fair value on the total cost of discretionary wealth management.
The Adviser Client Relationship Most Firms Only Have With Half the Household
In most advised couples one partner owns the adviser client relationship. Bereavement, divorce and incapacity expose that. How to build it with both.
Autumn Budget 2026: What Advisers Should Do in the Eight Weeks Before 28 October
The Budget is on 28 October 2026. The risk in the run-up is not the tax changes, it is what clients do on the strength of speculation. A pre-Budget protocol.
The End of the Annual Review: What CP26/10 Means for Ongoing Advice Fees
The FCA proposes replacing the annual suitability review with periodic reviews set by client need. What CP26/10 changes for ongoing advice fees and firm value.