Consumer Duty and good outcomes: hope springs eternal

The name Dyson is nowadays most likely to conjure up images of vacuum cleaners. As someone with a modest background in number-crunching, I instead prefer to think of mathematician and theoretical physicist Freeman John Dyson.

 

A member of Princeton’s illustrious Institute for Advanced Study, Dyson came up with all sorts of amazing scientific ideas during his 96 years. His contributions spanned disciplines including astrophysics, quantum field theory, engineering, biotechnology and interstellar travel.

 

Of all his wonderful outputs, though, my favourite is nothing more than a pithy quote about prophecy. “The purpose of thinking about the future is not to predict it,” Dyson remarked, “but to raise people’s hopes.”

 

Maybe I was subconsciously taking the latter approach back in April last year. That was when I suggested in an article on these pages that Consumer Duty would ultimately lower the cost of financial advice.

 

The crux of my argument was that the initiative could be seen as a Trojan horse for price regulation. Eventually, I said, our industry and its stakeholders – clients foremost among them – would reap the benefits.

 

It seems safe to say this hasn’t happened just yet. But that doesn’t necessarily mean my prediction was wide of the mark – and it certainly doesn’t mean our hopes have been dashed forever.

 

Let’s first reflect on what has happened since I offered up that bold forecast. There’s no doubt that it has been a difficult time for adviser firms, but have there been any signs of positive progress?

 

On the whole, 2024 served up an unhappy illustration of the law of unintended consequences. Rather than fostering the “good outcomes” at the heart of its raison d’être, Consumer Duty widened the advice gap.

 

We’re all familiar with how this saga panned out. To cut a long story short: a slew of new administrative requirements convinced many businesses that servicing their smaller clients was no longer worth the bother.

 

According to a report published at the end of the year, Consumer Duty as much as doubled the time taken to deal with some cases. As a result, almost three quarters of advisers surveyed said they found it “increasingly challenging” to accommodate clients with “lower asset values”[1].

 

This trend continued into 2025. Questioned for research published in June, two thirds of firms said they had raised their minimum levels of investable assets – with around 40% also admitting they had offboarded clients in light of the new regime’s demands[2].

 

Of course, even the Financial Conduct Authority (FCA) itself had warned “short-run costs” for regulated businesses were likely to go up[3]. Yet a consequent further thinning out of our industry’s client base isn’t exactly a winning look, to say the least.

 

On the face of it, then, my rose-tinted ideal of cheaper financial advice – and, by extension, the prospect of more clients rather than fewer – seems a bit far-flung at the moment. But let’s see if we can honour Dyson’s maxim by raising hopes again.

 

I think there are two well-worn issues at play here. The first is that too many adviser firms are only too delighted to have no truck with the world of “lower asset values”. The second is that too many adviser firms are only too delighted to let the regulator dictate their every move.

 

I don’t fall into either of these camps. I believe it’s eminently possible – not to mention essential – to deliver good outcomes for a wide range of clients, and I also believe the key to realising that noble goal is to get off your backside and help shape your own destiny.

 

It’s easy for a business to complain Consumer Duty is making life tough. It’s easy to protest that the only realistic course of action is to restructure fees – in other words, put them up – and send some clients packing. Maybe above all, it’s easy to blame the FCA for everything.

 

But there are alternatives to such copouts. One is to take the exigencies of Consumer Duty on the chin, recognise the potential for healthy evolution and do something in the long-term interests of the adviser community and the millions of individuals who place their trust in us.

 

In my view, the most useful response is to invest. More so than ever before, the right combination of people and tech can go a long way towards assembling an array of services that could at last help narrow the advice gap.

 

Consumer Duty should hammer home the message that the days of a one-size-fits-all approach to advice are well and truly over. It’s ridiculous to keep trying to foist the same bells-and-whistles, extra-festooned offering on all and sundry and then plead innocence whenever someone baulks at it.

 

How about instead recognising there are many clients who are happy to accept something much simpler? How about accepting they should have the opportunity to pay accordingly?

 

Call me crazy, but you never know – it could catch on. And if it does – well, my prediction might just came true after all. In the spirit of Freeman John Dyson, let’s not give up hope just yet.

 

Andrew Goodwin is co-founder and CEO of Truly Independent and the author of ‘The Happy Financial Adviser’.

 

[1] See, for example, Octopus Money: “Unlock your firm’s potential”, December 2024 – https://octopusmoney.com/wp-content/uploads/2024/12/Octopus-Money-Unlock-your-firms-potential-Whitepaper.pdf.

[2] See, for example, Professional Adviser: “Consumer Duty two years on: challenges remain for advisers”, 31 July 2025 – https://www.professionaladviser.com/news/4517111/consumer-duty-challenges-remain-advisers.

[3] See, for example, Frontier Economics: “Economic impact of the FCA’s Consumer Duty”, July 2021 – https://www.fca.org.uk/panels/practitioner-panel/publication/cp_21-13_new_consumer_duty_-_frontier_report_for_the_fca_practitioner_panel.pdf.