Fair value remediation for a legacy fee structure

The challenge

The firm had completed its initial Consumer Duty mapping but had not proactively monitored whether its ongoing advice fees were delivering fair value in practice across older, closed-book products. FCA data sweeps flagged the firm as a statistical outlier on client charges versus portfolio performance, and it lacked the proactive management information needed to evidence value.

Regulatory context

The Consumer Duty fair value outcome, and the FCA's use of data analysis to identify firms whose charging structures on legacy products were not being actively monitored for value.

What MEMA did

• Ran a retrospective data analysis of the affected client cohorts
• Identified the point at which value had eroded across the legacy fee structure
• Designed a costed, evidence-backed remediation and redress plan
• Built the management information needed to evidence fair value going forward

Outcome

A costed, evidence-backed remediation plan and a proactive fair value evidence base, giving the firm a credible position to put to the FCA.