Specialist dispute resolution & regulatory defence

Defensible Outcomes. Forensic Redress. Strategic FOS Resolution.

We support advice networks, IFAs, wealth managers, platforms and SIPP providers in managing high-stakes disputes under the FCA's DISP framework. Drawing on direct tenure as a Financial Ombudsman Service investigator and extensive experience with complex IFA casework, we build technically sound defence submissions, perform complex loss calculations and extract actionable root-cause intelligence to meet Consumer Duty requirements.

The Real Cost of Ineffective Dispute Resolution

Complaints in regulated wealth management and pensions are rarely simple customer service friction. They are technical disputes that touch on suitability boundaries (COBS), administrative dealing lag, statutory tax triggers, and defined benefit transfer or pension switching advice.

When firms treat complaints as purely administrative tasks, two costly outcomes follow:

  1. 01

    Defensible advice is conceded unnecessarily, because the investigation lacks the regulatory precision to counter weak arguments.

  2. 02

    Systemic operational failures are overlooked, creating repeat complaints, FOS case fees and avoidable distress-and-inconvenience awards.

We provide independent, senior-level intervention at every stage of the dispute lifecycle, so your responses are compliant, defensible and aligned with the Ombudsman's approach.

Dispute lifecycle

  1. 1 Forensic Investigation
  2. 2 DISP Final Responses
  3. 3 FOS Defence Submissions
  4. 4 Redress Calculations
  5. 5 Consumer Duty Root-Cause MI

What we do

A

Technical Complaint Investigations

Objective: Deep-dive case analysis across complex financial products.

  • Suitability and advice assessments across DB transfers, SIPPs and alternative investments, and drawdown strategies.
  • Technical audits of adviser charging, ongoing servicing and inheritance tax and trust structures.
  • Investigation of operational breakdowns, including platform settlement drag, out-of-market delays and unnotified Money Purchase Annual Allowance (MPAA) triggers.

B

DISP-Compliant Final Response Letters

Objective: Issuing sound responses within the eight-week DISP time limit.

  • Clear, objective and defensible final responses that follow DISP 1.4 and DISP 1.6.
  • Correct FOS referral rights and, where relevant, time-limit arguments under DISP 2.8 (six years from the event, or three years from when the complainant knew or ought reasonably to have known).
  • Complex technical reasoning presented in plain language that meets the Consumer Duty understanding outcome.

C

FOS Referral Management & Strategic Defence

Objective: Defending your firm's commercial and regulatory position when a complaint escalates to the Ombudsman.

  • Detailed, evidence-backed submissions that anticipate how investigators and ombudsmen assess what is "fair and reasonable".
  • Responding to investigator views with the relevant rules and contemporaneous evidence.
  • Managing institutional risk, published decisions and FOS case fee exposure.

D

Forensic Redress & Loss Calculations

Objective: Calculating precise compensation where an error or unsuitable recommendation has occurred.

  • Pension and investment reconstruction calculations that return the client to the position they would have been in but for the failure.
  • Redress for market-movement loss, settlement delays and tax consequences, such as avoidable emergency tax or MPAA breaches.
  • Assessing appropriate awards for distress and inconvenience in line with the Ombudsman's published approach.

Turning Disputes into Consumer Duty MI

Under PRIN 2A, complaints can not be handled in isolation. Firms are expected to identify root causes systematically and show that systemic issues are being fixed. Every dispute we manage feeds into our root-cause framework:

Root-cause framework for complaints
Failure CategoryOperational IndicatorRegulatory Risk Addressed
Pensions & Platform Drag Execution lag between instruction validation and trade settlement. Foreseeable harm under PRIN 2A.2 and COBS best execution.
Statutory Notice Failures Omission of the flexible access statement following an MPAA trigger event. Statutory non-compliance (SI 2006/567) and client tax exposure.
Servicing & Fee Disclosures Failure to evidence ongoing reviews against recurring adviser charging. Consumer Duty price and value outcome breaches.
Vulnerable Customer Harm Red flags missed in transactions for clients experiencing distress or cognitive decline. FCA vulnerable customer guidance and SYSC systems and controls.

We turn isolated complaint data into clear, defensible board reports and MI dashboards, so Compliance Directors and SMF holders can demonstrate proactive governance.

Pension Settlement Dispute

Client: IFA network · Area: Pension disinvestment / settlement · Service: FOS Defence & Redress · Claim: £35,000

Case Study: FOS Defence & Pension Settlement Dispute

Context. An IFA network faced an escalated FOS complaint after a client withdrawal request. Multi-asset disinvestment settlement delays caused the client to miss a property purchase completion deadline, and the complainant claimed £35,000 for market-movement losses and consequential distress.

Our action. We carried out a forensic audit of the whole operational chain, separating platform dealing cut-offs, fund manager valuation points and adviser communication logs. We showed that the IFA had told the client about fund settlement timeframes in line with COBS disclosure rules, and we identified an uncommunicated internal platform clearance hold as the primary cause of the delay.

Why partner with us

  • Former FOS Investigator Insight

    Direct experience of the full lifecycle of Ombudsman disputes, and an insider understanding of how cases are decided and how to structure an effective submission.

  • CISI Level 6 Technical Depth

    Qualified in Pension Transfers & Planning Advice, for peer-to-peer technical evaluation of complex DB transfers, SIPPs and decumulation strategies.

  • Bridging Operations and Conduct Rules

    We understand how platform operations, trading desks and payroll software interact with DISP, COBS and SYSC.

Need Senior Support with an Escalated Dispute or Backlog?

Whether you're facing a contentious FOS referral, need complex pension redress modelling, or want an independent reviewer to clear a complaints backlog under DISP rules, contact Compass Compliance Consulting for a confidential consultation.