Fair value evidence and a remediation plan for legacy fees
A wealth manager had mapped its products for the Consumer Duty but was not checking whether ongoing advice fees on older, closed-book products still gave fair value. MEMA built the evidence and a costed remediation plan.
- CostedRemediation and redress plan
- OngoingFair value evidence
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 we did
- Analysed the history of the affected client groups
- Found the point at which the legacy fees stopped giving fair value
- Designed a costed, evidence-backed remediation and redress plan
- Built the management information to evidence fair value from then on
The 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.
Client details are presented to protect confidentiality. Outcomes reflect specific engagements and are not a guarantee of results, as every firm's circumstances differ.
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