Insights
Notes from the file room
Commentary on FCA policy, AI governance and the practical business of checking advice files, written from what it actually takes to run an AI reviewer in production for UK advice firms. Views are our own, and none of it is regulatory advice.
Simon Owen
Commercial Director, IntegrityAI
Simon Owen is Commercial Director of IntegrityAI and a Fellow of the Personal Finance Society, with 20 years’ experience in financial advice and regulatory compliance. He has worked with global banks and FTSE-listed firms on complex regulatory projects, and contributed to the CII’s learning materials on ethics and regulation.
What the pension IHT change means for the files sitting in your back book
From April 2027 unused pension funds fall into the estate for inheritance tax. Much of the advice in a typical back book was written on the opposite assumption, and a file check needs to find the files that still rest on it.
Vulnerable clients, the distribution chain, and what a file actually needs to prove
The FCA now reads FG21/1 through the Consumer Duty. With a joint statement from the FCA and ICO and a live consultation on the distribution chain, what a file must show about a vulnerable client has moved.
Consumer Duty, Year 3, and the evidence a board report can’t manufacture on its own
Three FCA reviews in 2026 point the same way: firms have built the governance, but few can prove the outcomes file by file. That is the gap a Year 3 board report cannot close on its own.
What the Mills Review means for compliance file checking
The FCA’s review of AI in financial services proposes no new AI rulebook, it points firms back at the Consumer Duty and SM&CR, and asks for accountability, auditability and human oversight designed in from the start. Here is what that looks like in a file-checking process that already runs that way.
See how a review is actually put together
Frank reads the file, grades it Red, Amber or Green, and shows his reasoning against the source documents. A human reviewer signs it off, every time.
Walk through a review