So, it turns out that grabbing a coffee and a slice of chocolate cake counts as an “advice review”—at least according to the FCA’s interim executive director of markets, Simon Walls.
Yes, you read that right. That £10,000 ongoing adviser charge? As long as an adviser could show that some kind of review took place—no matter how meaningless—the regulator gave them the thumbs up.
‘It was not focused on the quality of the review, it was focused on the existence of the review,’ Simon Walls said.
The FCA’s recent review of 22 major advice firms found that 83% of clients supposedly received their promised annual review. But here’s the kicker: Walls admitted that this wasn’t about quality—only about whether a review existed. In other words, it didn’t matter if it was a deep financial review or just a friendly chat over coffee.
Good News for Advisers, Bad News for Clients
Advisers breathed a sigh of relief. Complainants and claims management companies (CMCs) despaired. And the FCA? It looked like it was sweeping this issue under the rug as part of the government’s “growth agenda”—keeping big firms happy and avoiding any disruption to the financial advice gravy train.
But here’s where things get interesting.
MiFID II Says Otherwise
Under MiFID II regulations, ongoing advice reviews don’t just need to be offered—they need to be delivered. That means the 15% of cases where clients were “unreachable” or “unwilling to engage” could still be subject to a legal challenge.
And even for the firms that did tick the review box, the law demands substance. The review must provide actual value to the client—not just be a tick-box exercise. If challenged, the FCA’s 83% compliance rate could collapse like a house of cards.
A Pointless Exercise?
What was the point of this FCA review?
If the definition of a review is so vague that coffee and cake qualify, then the whole thing is meaningless from a legal perspective. Instead of protecting consumers, it appears the regulator is misleading the entire industry into thinking there’s nothing to see here.
But there is. And the fight isn’t over.
What Happens Next?
The FCA has promised to keep an eye on “laggards”—firms that are slow to deliver ongoing reviews. But if the bar is this low, is there really any incentive for firms to do better?
The next battle will be fought on two fronts:
1️⃣ Legal Challenges: Those 15% of clients who didn’t receive their reviews could still have a case. Under MiFID II, firms must prove that they delivered the service, not just offered it.
2️⃣ Defining Real Value: The FCA now faces pressure to define what an advice review actually is. If it fails to do so, this could erode trust in financial advice altogether.
Final Thought
This should have been a moment for the FCA to restore confidence in ongoing advice services. Instead, it’s left the door open for low-value, high-cost “reviews” that do little more than justify fees.
So, advisers may be celebrating now. But if consumer advocates and legal experts step up, this issue could be far from settled.
What do you think? Should a coffee and cake meeting count as a £10,000 advice review? Let me know your thoughts.
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