By Steve Conley, Founder, Academy of Life Planning
The FCA’s Consultation Paper CP25/17, “Supporting consumers’ pensions and investment decisions: proposals for targeted support,” sets out to close the so-called “advice gap” through a new regime of cohort-based recommendations. But to those of us working to empower individuals, not intermediaries, this paper represents a step backwards—toward market-led control disguised as consumer care.
Here’s why.
🧘♂️ 1. In the Aquarian Age, There Is No Advice Gap
The notion of an “advice gap” arises only when we accept a Piscean paradigm: that advice is tied to intermediation. In reality, generic advice—advice not tied to the sale of products—is already widely available and lawfully delivered without FCA authorisation. Empowered individuals, equipped with the right tools and education, can make well-informed decisions without delegating power to an industry that has too often prioritised growth over wellbeing.
In this new era, we no longer need an FCA, FOS, or FSCS to protect us from bad actors—because we are removing the actors altogether.
🧯 2. Targeted Support Is a Sales Strategy Masquerading as Help
What is “targeted support,” if not an industry strategy to capture the underserved 90% and convert them into product consumers—without the protections of regulated advice?
- There’s no recourse for mis-selling.
- There’s no complaints pathway.
- There’s no redress scheme.
It’s a non-advised sale delivered under the banner of “support,” and it transfers all risk to the consumer while transferring new sales to the market.
This is not a consumer-centric initiative. It’s a market growth strategy in disguise.
🎭 3. Segmenting Humans Is Not the Same as Serving Humans
Targeted support is based on a dangerous logic: “People like you did this, so you should too.”
But people are not segments. And vulnerable consumers do not benefit from generic nudges based on assumptions. They benefit from understanding—not manipulation.
Instead of addressing the true barrier (a lack of confidence, literacy, and agency), CP25/17 proposes solutions that prey on information asymmetry rather than correcting it.
🌿 4. Holistic Does Not Mean Product Bundling
The paper repeatedly uses the term “holistic advice” to imply a broader basket of financial products. But that is a distortion of the word.
Holistic planning means advising the whole person—their goals, values, circumstances, and aspirations—not stacking products to increase assets under management.
If the aim is to serve the person, then holistic planning should be product-free, values-led, and designed to align life goals with financial architecture—not the other way around.
🤖 5. Use AI to Empower, Not Intervene
The consultation makes passing mention of AI as a tool for firm productivity—but misses the transformative opportunity. AI can remove barriers to entry for consumers, flatten power hierarchies, and democratise knowledge.
Rather than building AI tools for firms to sell more, we should build AI mentors for individuals to learn, plan, and take control. This is what the GAME Plan and AI Life Planner models offer: accessible frameworks for decision-making, owned by the people.
🧨 6. Dangerously Lowering the Bar for High-Risk Product Access
By setting the threshold for targeted support at £10,000, the FCA opens the gates to retail product sales for those who can least afford the risks:
- £10,000 is often not surplus but the only buffer for emergencies or short-term needs.
- Many in this bracket are risk-averse or vulnerable, including pensioners.
- The proposal creates a clear incentive for firms to push higher-risk or higher-margin products on low-risk consumers.
This is not consumer protection. It’s regulatory rollback, undoing decades of safeguards to appease banks and insurers under the guise of innovation.
🌊 Conclusion: Empowerment, Not Exploitation
CP25/17 may be framed as a consumer initiative, but at its heart, it is a growth-driven market access agenda, designed to increase flows of retail capital into investment products—without increasing consumer confidence, understanding, or protection.
In the Age of Aquarius, empowerment comes not from delegation, but from self-direction.
It’s time to:
- Prioritise generic advice and financial education.
- Enable peer-led, community-based guidance.
- Deploy AI to equalise power, not centralise it.
- Protect people not through segmentation, but through sovereignty.
We must move from a system designed to extract wealth to one that builds it—within and among the people themselves.
Further reading:
Be Your Own Financial Adviser by the brilliant Jonquil Lowe
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