From advice to execution: Part 3 of Patrick Murphy’s insights on the FCA’s simplified advice model

The FCA has recently published one of the most important consultation papers in years, on simplifying pensions and investment advice.  

Last week, IFA Magazine published two of a three article mini-series on the subject, written by Patrick Murphy, Sustained Momentum, someone with more than 50 years’ of practical experience in the Financial Planning profession.

Patrick has taken the time to highlight why the FCA is running this process, something he is clearly very passionate about. Below, we bring you Patrick’s third and final article, which is focused on what the next model actually looks like, not just through a Consumer Duty lens but through a commercial one too.

In my first and second articles on this simplifying advice consultation, which have been published here on IFA Magazine over the past week or so, I set out how the advice gap was created — and why the FCA’s current consultation, while directionally right, may not fully address the real issue.

That’s because the issue is not just access to advice. It is what happens after advice is given. Because outcomes are not determined by recommendations alone. They are determined by behaviour. And under Consumer Duty, that distinction now matters commercially.

The problem with the current model (through a Consumer Duty lens)

The traditional advice model is built around a moment in time, and that’s the recommendation. Everything is designed to support that moment including the need to:

gather information 
assess risk 
produce a suitability report 
implement 

After that, the industry defaults to periodic reviews (typically annual).  And, from a historic compliance perspective, that made sense. However, from a Consumer Duty perspective, it is increasingly difficult to justify. Why? Because Consumer Duty is not asking the question: “Was the advice suitable at the point it was given?” It is asking: “Did the client achieve a good outcome?” And that is driven by behaviour over time.

Annual reviews vs real outcomes

Let’s consider these two. Annual reviews provide structure. They create a record, support governance, but they do not manage behaviour. Clients do not make poor decisions once a year. They can do it:

when markets fall sharply 
when headlines create fear 
when cash builds up unnoticed 
when life distracts them from acting 

So we have a structural gap: and that’s that we have a periodic service model trying to deliver continuous outcomes.  From a Consumer Duty perspective, that creates risk and from a commercial perspective, it creates inefficiency.

The commercial reality for IFAs

Most firms are currently delivering the following:

high-cost, adviser-led annual reviews 
Inconsistent client engagement between meetings 
limited visibility on whether clients are actually following plans 

Which means that:

time is spent where it adds least value 
disengaged clients remain on the book 
outcomes are variable (and hard to evidence) 

Under Consumer Duty, that becomes harder to defend. And commercially, it limits your scalability.

The opportunity created by the FCA consultation

With this consultation, the FCA is removing constraints namely:

less prescriptive suitability requirements 
no mandated annual reviews 
greater emphasis on proportionality 

This is not just regulatory change, it is a commercial opportunity to redesign the service model.

What replaces the annual review model?

To my mind, the shift is from periodic advice  to continuous, structured engagement. And this is where technology — and increasingly AI — becomes essential.

What this looks like in practice (and why it benefits firms)

1. From annual meetings to continuous nudges, instead of one high-cost annual interaction, firms deliver:

short, relevant prompts 
timely reminders 
simple check-ins 

For example:

“Markets are volatile — here’s what we agreed and why it still holds.” 
“You’ve built up excess cash — shall we review your next step?” 
“You’re ahead of plan — here’s what that means for your options.” 

The commercial benefits of this approach are impressive, as I’ve identified below:

lower cost per client interaction 
higher perceived value 
increased client engagement without adviser time 

2. Behavioural risk monitoring (Consumer Duty in action)

Rather than assessing risk once, firms monitor behaviour continuously.

Signals include:

repeated logins during market stress 
switching or withdrawal patterns 
lack of engagement over time 

These create early warning indicators, allowing firms to intervene before poor outcomes occur. The Consumer Duty benefit is therefore proactive support, not reactive review. The commercial benefit is that fewer client mistakes, better retention, lower complaint risk.

3. Guided decision pathways (reducing friction)

Instead of long reports, clients are guided through decisions. For example:
“You have £50,000 in cash — here are your three realistic options.” 
“Here’s the impact of doing nothing.” 
“Here’s the impact of acting.” 

The commercial benefits here could be:

faster decision-making 
higher implementation rates 
less adviser time per case 

4. Measuring what actually matters: persistence

Today, most firms measure:

assets 
revenue 
compliance outputs 

But Consumer Duty is pushing toward something else, and that’s outcomes over time. This means tracking the following:

implementation rates 
time to action 
persistence of decisions 
client engagement levels 

However, the commercial upside of this is that, firms that can evidence outcomes will differentiate and defend value.

Why technology (and AI) is the enabler

Without technology, this model is impossible. That’s because, purely through human advisers, you simply cannot:

contact clients regularly 
monitor behaviour 
deliver timely interventions 

On the flip side, by using technology, you can:

scale engagement across hundreds or thousands of clients 
automate routine interactions 
focus human time where it adds most value 

This is not about replacing advisers. It is about amplifying them.

Bringing this back to the consultation (and your response)

If you’ve read the consultation — and my first two articles — I’d hope that you will likely agree with the direction of travel, which, just to sum up is more flexibility, more proportionality and more access.

But the consultation does not yet fully address how outcomes are actually delivered. And this is where your response to the FCA’s consultation really matters. Because the FCA is explicitly asking for industry input. So instead of simply agreeing with the proposals, consider adding your perspective on:

the need for ongoing engagement, not just point-in-time advice 
the role of behavioural support in delivering good outcomes 
how firms can evidence persistence and follow-through 
how technology can enable scalable, proportionate ongoing services 

Might I also suggest that you don’t just respond to what is written, respond to what is missing.

Why you should respond (even if you haven’t before)

I believe that most advisers won’t respond by the deadline of 22nd May, and that would mean that the final framework will be shaped by a relatively small number of voices. At the same time, this consultation will directly influence:

how you deliver advice
how you structure ongoing services 
how you are assessed under Consumer Duty 

This is not abstract, it will affect your business model.

A simple way to approach your response

You don’t need to write a technical paper, you just need to start with three questions:

What stops us serving more clients today? 
What would help us deliver better outcomes consistently? 
What role should ongoing engagement and behaviour play in this? 

And, if you answer those honestly, that alone will be more valuable than most responses.

A final thought
The FCA is opening the door here, and Consumer Duty is raising the bar. Alongside these, technology is making new models possible. So the real question is not: “How do we simplify advice?” It is: “How do we ensure clients actually do something with it — and keep doing it?” f you have a view on that… now is the time to tell the FCA.
Because if the profession doesn’t shape this… someone else will.
Want to know more?

For advisers who want to explore the consultation further or sense-check their response, you can use the Ask Patrick assistant via the Targeted Support website here: targeted.support | Targeted Support Implementation by Patrick Murphy”

Respond to the FCA by 22/05/2026

The closing date for the FCA’s consultation CP26/10, entitled ‘Simplifying the pension and investment advice rules’, is 22^nd May 2026. You can submit your response to the FCA using this link: https://www.fca.org.uk/publications/consultation-papers/cp26-10-simplifying-pensions-investment-advice-rules

About Patrick Murphy

Patrick Murphy is one of the UK’s most experienced and respected financial planners, with over 50 years in the profession. He built and sold his award-winning firm, Zen Wealth LLP, after a long career that included winning numerous industry awards.

Patrick now leads Sustain Momentum Ltd, where he is exploring the use of AI, mindset, and modern strategy. His work blends deep technical knowledge with the human side of advice, helping advisers simplify their processes, elevate client experience, and enhance firm value.

His mission is simple: help advisers build better businesses, serve more people, and lead happier, more purposeful lives.