The FCA's Outcomes Monitoring Review Is Good News for Small Advice Firms

Most advice firms collect more client information than they ever get time to look at. Fact-finds, review notes, service standards: the raw material is all there, spread across systems that don't talk to each other.

On 27 July the FCA published the findings of its review into how firms monitor customer outcomes under the Consumer Duty, alongside a blog from Charlotte Clark, its director of cross-cutting policy and strategy. For smaller firms, the message is more encouraging than a regulatory review usually manages to be.

What the FCA published

The review, "Outcomes monitoring: good practice and areas for improvement", looked at firms of different sizes and business models across sectors. The FCA assessed board reports, sent information requests, and surveyed 56 firms on their monitoring strategy, their use of data and MI, and their governance.

The test it sets out is plain. Collecting data or reporting MI does not, by itself, show that clients are getting good outcomes. A firm should be able to explain four things: what its information tells it, how it uses that to spot risks, what action it takes, and whether the action worked.

The section small firms should read first

The review addresses smaller firms directly, and the wording matters. The FCA says smaller firms can use a focused set of indicators "without complex systems or large teams". What counts is being able to explain what your information shows and what you do in response.

The good practice it highlights is ordinary work done properly. Firms described a good outcome for each key stage of the client journey in plain language: clients understand the product, get timely support, and don't face avoidable delays. Then they checked against indicators they already had. Complaints. Client feedback. Missed service standards. File checks.

No new committee, no data warehouse. A short list of meaningful measures and a clear line from what you see to what you do.

Where firms come unstuck

The weaknesses the FCA found are worth sitting with. Some firms relied on reactive or poorly defined indicators. Some lacked clear audit trails. Some couldn't show how their data led to a decision, or whether the fix improved anything.

Most of those gaps trace back to where the information lives. When client records sit in one system, servicing tasks in another and complaints in a spreadsheet, the connecting evidence has to be rebuilt by hand every time someone asks for it.

What it means for the firms we build for

This is the thinking behind Glimzer, our CRM and practice management platform for UK financial advice firms. When enquiries, pipeline, new business and ongoing servicing live in one place, the audit trail accumulates as a by-product of doing the work. Review dates don't slip silently. Service standards are visible while there's still time to act on them, not in a year-end reconstruction.

As Charlotte Clark put it in the FCA's blog: "The firms making the strongest progress aren't necessarily collecting more information. They're using it more effectively to understand their customers, identify harm earlier and drive meaningful improvements."

The regulator's bar is being able to explain what your information shows and what you did about it. Clean records make that a short conversation.

What's next

The third annual Consumer Duty board report falls due on 31 July, so the review's timing is pointed. But outcomes monitoring is a year-round discipline, not a July scramble, and the FCA has said firms should use the review to check whether their own approach gives them a clear enough view. The firms in the strongest position next July will be the ones whose evidence built itself through the year.

If you run an advice firm and you've ever wondered whether there's a better way to manage your pipeline and your ongoing client work, we're always happy to show you around. You can see Glimzer for yourself at glimzer.com.