Turning suitability reviews into a strategic advantage

TCC and Recordsure’s AI for compliance webinar series included a focused discussion on suitability reviews. The second excerpt explored how firms can move beyond tick-box checking to improve client outcomes, reduce rework and strengthen adviser performance.

Suitability review can genuinely improve client outcomes when firms stop simply ticking boxes. Advice file rework also creates delays in demonstrating that suitable advice has been delivered.

The hidden costs of poor suitability checks

The webinar asked what proportion of advice files currently need rework after a suitability review. Almost half of respondents, 42%, said between 10 and 20% of files. Another 29% said between 20 and 30%, and 29% said less than 10%. No respondents said more than 30%, and 0% were unsure.

The findings reflect a familiar issue: even where checks exist, files can receive unclear ratings that take advisers away from profitable activity, create additional work and delay evidence that suitable advice was delivered. For some firms, a rework rate below 10% is almost unheard of.

Garry Evans asked the audience to consider the hidden costs of suitability checking done badly and high levels of unclear ratings. He noted that many past clients would have sat in the more-than-30% category for cases needing rework or receiving an initial unclear rating.

The result revealed a spread of experience across the industry, with no firms indicating that more than 30% of cases required rework and some reporting less than 10%.

The finding underscores the reality that many clients’ cases initially carry unclear ratings. Those ratings create inefficiencies and additional work, and can take advisers away from other activities.

Meeting regulatory expectations

TCC’s Technical Director, David Boyhan, discussed the FCA’s expectations for risk-based sampling. He noted that the point had been reinforced by Lucy Castledine, Director of Consumer Investments at the FCA, during the PIMFA conference.

The regulator expects firms to focus monitoring on higher-risk interactions with clients, including both new product recommendations and ongoing advice. Suitability should be assessed consistently across client touchpoints.

The webinar identified reviewing around 10% of files as good practice, with higher volumes for higher-risk areas such as new advisers or complex products including drawdown and VCTs. Results should inform future sampling volumes: positive findings may allow lower review volumes, but short- to medium-term monitoring remains important to evidence suitable client outcomes.

David Boyhan said the timing was relevant because the FCA’s expectations around sampling had been amplified by Lucy Castledine’s speech. He explained that, as a risk-based regulator, the FCA expects firms to take a risk-based approach to monitoring.

He also said initial and ongoing advice files need to be reviewed in sampling models. Historically, some models focused on initial advice, but ongoing advice is now a key part of many business models and needs monitoring for suitability.

David Boyhan said monitoring should cover where there is a new product recommendation and where no new products are recommended. Volumes should be increased in high-risk areas and informed by the findings of previous file reviews, so good outcomes can be evidenced over time.

He described around 10% of file reviews as generally seen as good practice, while recognising that high-risk products and new advisers may require more. Where findings are positive, review volumes could be decreased, but the key is to keep monitoring outcomes over the short to medium term.

David Boyhan highlighted that the regulator’s expectation is continuous monitoring rather than one isolated sample. He outlined that the range should be adjusted where risk is higher, and that reductions are only appropriate where evidence supports them.

A collaborative review process

Neil Dethick explained that TCC starts by understanding the firm’s business, including detailed discussions with compliance teams, review of advice policies and standards, and understanding of the advice and sales process.

Where a file is rated unclear or unsuitable, the process provides a concise 15-minute pathway to suitability. Advisers and paraplanners are engaged through case clinics, workshops and training videos so insights are acted upon rather than simply reported.

The process also includes commentary on evidence of adherence to the four Consumer Duty outcomes in each file review, building board-level MI on how the firm is delivering good client outcomes.

Neil Dethick said that an end-to-end collaborative review service starts with understanding the nature of the business being reviewed. That includes discussion with compliance teams, examination of advice policy and standards, and understanding the advice and sales process.

He explained that TCC communicates directly with advisers and paraplanners through case clinics, and provides bespoke best-practice workshops and videos to support adviser development. File reviews also include commentary on evidence against the four Consumer Duty outcomes.

The process is intended to provide a tangible pathway to resolution whenever a file is unclear or unsuitable. It is not only a file-checking exercise: it uses consultation, case clinics and adviser development to make sure the findings are understood and acted on.

Adviser and paraplanner engagement is central. The review output is accompanied by clear steps, best-practice support and management information that can be taken to boards.

This differs from a narrow check because it is structured as a collaborative, end-to-end process. It aims to explain what needs to happen, provide actionable resolution steps and make sure adviser development is documented.

Driving real change

TCC also provides monthly or quarterly reporting on findings, key themes and trends, with recommendations for future process improvements from advisory subject matter experts.

Firms working with TCC over the past ten months improved right-first-time rates from the low 60s to nearly 90%. Aggregated percentages built over that period and almost reached 90% in the latest month.

Feedback only matters if recipients use it to drive behavioural change. Suitability reviews are most effective when detailed analysis, clear guidance and follow-up are combined.

Firms seeking similar improvements can enhance adviser performance, strengthen compliance and turn suitability reviews into a business advantage.

Neil Dethick described reporting on findings, key themes and trends at monthly or quarterly intervals. Subject matter experts in the advisory team can then recommend process improvements.

Garry Evans framed the improvement as an example of partnership, noting that feedback, MI and intent do not make a difference unless the recipient uses the information to drive behavioural change.

The full webinar was positioned as a way to explore the TCC suitability review process in detail, see how AI can support but not replace human expertise, and identify practical ways to reduce rework while improving client outcomes.

Comprehensive reporting covers the findings, themes and trends noted through the review process. Those reports can then support recommendations for process improvement and help firms understand where advice standards, policy or training need attention.

The full webinar explains how the process works, how AI can support but not replace human expertise, and how practical changes can reduce rework while improving client outcomes.

The change was a dramatic turnaround, with suitability ratios improving as the programme built over time. It is a measurable example of what can happen when firms integrate feedback into operations.

The closing message was that firms can achieve similar improvements by acting now: strengthening compliance, improving adviser performance and turning suitability reviews into a genuine business advantage.