The FCA’s information request has been the hottest topic this summer – and has made up the bulk of the work we’ve been doing with our firms since the news broke.

From most firms, the initial reaction to the 28 question information request has been, “Could have been worse.” But later, there’s a new reaction… “HOW am I supposed to get that data?”

It’s a good question… Let’s discuss.

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What does the FCA information request 2025 ask for?

Mostly, the questions relate to information that firms will ‘just know.’ The basics.  

But there are some fiddlier bits, including:

• Client gender split

• Reasoning for initial advice

• Firm Reference Numbers for third parties

• File checks

Let’s break some of these down a bit further.

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FCA information request: Reasoning for initial advice

On this one, don’t overthink it. The most frequently asked questions have been around the ‘reasoning for initial advice.’ The FCA is trying to ascertain why people access financial advice. We know that most people have multiple objectives, so use the free text box to explain this.  

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FCA information request: File Checks

Remember how, way back in 2020, the FCA cancelled their Assessing Suitability Review 2? Outside of the Ongoing Services Review, and the Retirement Income Review, they haven’t really had eyes on the industry. This is likely the start of their data-led approach, focusing on the biggest risk for the advice sector… the advice itself!

With that in mind, the FCA wants to understand:

• your firm’s risk strategy regards mitigating unsuitable advice

• remedial actions where you have highlighted potential unsuitable advice or poor outcomes

• where it is recorded

Typically, we’d expect a firm’s file checking process to be aligned with an adviser’s competency, and the risk of the advice being given.  

Post-sale checks on a 10% basis for competent advisers is fairly standard – and then pre-sale on higher risk areas, or areas less frequently advised.  

Many firms conduct internal checks, but these often look at disclosure and process. Firms should also question who is challenging the fundamental suitability of the advice, as this is ultimately what could lead to the costliest of complaints should anything go wrong.  

And just how wrong can things go? Well, here’s the Decision Notice from the FCA on Neil Woodford. An interesting read!

FCA information request: Back-office selection

Away from that exciting read, the Information Request has also challenged firms to look at processes including back-office selection.  

The FCA has very much emphasised their position as the soon to be data-led regulator, so there is a potential for more of this information to be requested on a more frequent basis. 

Back-office systems should provide clear workflows, ensure consistent data entry and accessibility. But if you’ve read my 5 step framework to reducing compliance risk, you’ve already sorted that.

One final note on the FCA’s Information Request: ensure you submit by your firm's deadline!

As always, me and the Compliance team are on hand to roll up our sleeves on any of the above – give us a shout when you’re ready.