Fair value & ongoing advice assurance
Ongoing adviser charging (OAC) is one of the most closely supervised areas of retail advice. Under PRIN 2A.4 and the FCA's fair value expectations, firms must be able to prove, client by client, that recurring fees match a service genuinely delivered. We conduct independent, file-by-file reconciliations that cross-reference fee deductions against documented, substantive annual suitability reviews. We find and fix the gaps before a regulator, a claims firm, or the Ombudsman does.
For years, ongoing advice was evidenced by its income: the retainer was collected, so the service was assumed. That assumption no longer survives scrutiny. FCA supervisory work on ongoing advice services, combined with the Consumer Duty's Price and Value outcome (PRIN 2A.4), has shifted the burden firmly onto firms to evidence that clients actually received what they paid for.
The balance-sheet exposure is rarely confined to a single file. Unserviced accounts typically cluster in distinct risk pockets:
Without a structured reconciliation, the scale of the liability remains invisible until an FCA data request, transaction due diligence, or a wave of complaints makes it catastrophic. We map every fee-paying client to evidenced service delivery, quantify any shortfall, and provide a commercially defensible plan to remediate it.
A
Objective: Proving that every recurring charge is matched by delivered service.
B
Objective: Testing whether a recorded review was a substantive suitability reassessment.
C
Objective: Evaluating cost across the entire advice chain, not just the isolated adviser fee.
D
Objective: Putting things right fairly, consistently and defensibly.
Ingesting platform fee deduction ledgers, CRM diary stamps, and suitability review registers across all target cohorts.
Cross-referencing fee deductions against verified delivery milestones to isolate unserviced and disengaged client accounts.
Forensically auditing review files against COBS 9 and PRIN 2A to confirm suitability was genuinely re-evaluated rather than administratively signed off.
Calculating restitution for unserviced periods, factoring in fee refunds, statutory interest, and portfolio growth adjustments.
Delivering an audit-ready executive pack with Root Cause Analysis (RCA) and SMF16 escalation recommendations.
We know how ongoing fee disputes and "fee-for-no-service" complaints are assessed inside the Financial Ombudsman Service (FOS), and we construct our audit findings to that exact evidentiary standard.
We understand CRM ledgers, adviser review cycles, and Appointed Representative (AR) oversight dynamics, ensuring our findings are commercially grounded and operationally viable.
Led by a CISI Level 6 Pension Transfer Specialist (MCSI), we have the technical pedigree to evaluate whether a review was genuinely substantive or merely administrative.
We deliver fair, defensible outcomes for clients without making unnecessary commercial concessions on files that were properly serviced.
Whether you are preparing for an FCA data request, reviewing an acquired client book, or auditing historical ongoing adviser charging, contact Compass Compliance Consulting for a confidential assessment.
Practical implementation of PRIN 2A across advice and operations, with outcome-based MI and board dashboards that evidence good customer outcomes.
Explore this serviceCalibrated file testing, past-business reviews and Section 166 support, including complex AML and UBO audits, delivered to a standard that withstands regulatory challenge.
Explore this serviceContact Compass Compliance Consulting for a confidential discussion about an ongoing servicing audit, a client bank due diligence review or a fee-for-no-service remediation.