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Financial Advisory Launch Programme · Stage 4 of 10
Get Compliant
Build the firm around the standards the FCA sets, then have your network or compliance sign off how you meet each one.
How long
~1 week
You’ll have
An advice process built around Consumer Duty, plus suitability, AML and data handling
Steps
4 steps
Resources
2 resources
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01 Step 01
Step 01
Build your advice process around Consumer Duty
Consumer Duty is the overarching standard you operate under, and it reshapes what good advice means, so build your process around it from day one.
Do it yourself
- Understand the standard (PRIN 2A): act to deliver good outcomes for retail clients across four outcomes (products and services, price and value, consumer understanding, and consumer support), while acting in good faith, avoiding foreseeable harm, and supporting your clients’ objectives.
- Design your end-to-end advice flow, which becomes your Advise Your First Client module, so each stage evidences a good outcome.
- Build the fair-value evidence for the fees you set in your charging model.
- Keep it proportionate: a small firm’s approach should be proportionate to its size, not enterprise-scale.
Common mistake · Treating Consumer Duty as a one-off document rather than the operating standard baked into every client interaction and file.
Time~2–3 days to design CostFree DifficultyHighResource for this step
PDFConsumer Duty four-outcomes self-check
The four outcomes mapped to each stage of your advice journey.
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02 Step 02
Step 02
Set up your suitability and disclosure process
Suitability is the heart of regulated advice: every recommendation must be suitable and evidenced, and clients must get the right disclosures at the right time.
Do it yourself
- Build the suitability chain the Conduct of Business rules (COBS) expect: a fact-find, then a risk assessment, then research, then a suitability report documenting why the recommendation fits the client’s needs and objectives.
- Set up your disclosure documents: an initial disclosure covering who you are, your status and your services; your costs and charges; and your independent or restricted status.
- Bake in ongoing suitability reviews, at least annually wherever you charge an ongoing fee, because that is what the fee buys.
- Create a file-check discipline so every case is reviewable.
Common mistake · Suitability reports that describe the product but don’t evidence why it suits this client, the recurring FCA finding.
Time~2–3 days to template CostFree DifficultyHighResource for this step
PDFSuitability report and disclosure pack
A suitability-report skeleton and disclosure pack, marked as a template your network or compliance signs off.
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03 Step 03
Step 03
Stand up your AML process
As a regulated adviser you must prevent your firm being used for money laundering, a legal duty with personal accountability attached.
Do it yourself
- Put written AML policies, controls and procedures in place, proportionate to your firm, as the Money Laundering Regulations 2017 require.
- Build client due diligence: identity verification and ongoing monitoring for every client.
- Appoint a nominated officer (MLRO) responsible for AML and suspicious-activity reporting; in a one-person firm, that is you.
- Set up training and keep records.
- If you are an Appointed Representative, your network typically provides the framework and tooling, so implement theirs rather than inventing your own.
Common mistake · Copying a generic AML policy off the internet and never actually running client due diligence on your first clients.
Time~1–2 days CostPossible ID-verification tooling DifficultyMedium -
04 Step 04
Step 04
Lock down data protection and record-keeping
Advice generates highly sensitive records you must protect and retain, sitting alongside AML and Consumer Duty as a core ongoing obligation.
Do it yourself
- Build on your ICO registration: put GDPR and DPA-2018-compliant data handling, storage and retention in place.
- Define retention periods for client files and advice records, which run long-dated for advice.
- Secure your systems with encryption, access control and backups (this links to your software stack).
- Align data handling with your AML and Consumer Duty processes so it is one coherent system, not three.
Common mistake · Storing client data in ad-hoc spreadsheets and personal email instead of a secure, access-controlled back-office system.
Time~1 day CostFolds into your software cost DifficultyMedium
What you’ll have after this stage
- An advice process built around Consumer Duty’s four outcomes
- A suitability and disclosure process, with templates ready for sign-off
- A proportionate AML framework with a nominated officer
- Secure, compliant data handling and retention