Consumer Duty Monitoring Checklist for Financial Advisers

Important: This checklist is a practical aide to support your Consumer Duty monitoring process. It does not constitute compliance advice. You remain responsible for suitability assessments and adherence to FCA rules.

Know Your Client Outcomes

Document the specific client outcome each portfolio is designed to achieve.Record the client's risk tolerance, capacity for loss, and investment time horizon as of the last review.Confirm that the portfolio's asset allocation and individual holdings align with the stated outcome.Note any life events since the last review that may have changed the client's objectives.Flag any holdings that appear inconsistent with the client's stated risk profile.

Review Each Holding Against Current Research

For every holding, review the most recent research — do not rely on the purchase rationale alone.Check each holding's Longwalk Score (or equivalent assessment). Note any material changes.Identify holdings where the risk profile has deteriorated (score dropped, key risks materialised).For concentrated positions (>5% of portfolio), document a specific rationale for continued holding.Review any holding underperforming its benchmark by more than 10% over 12 months — is the thesis intact?Check for regulatory or legal developments affecting specific holdings.

Assess Portfolio-Level Risks

Review sector concentration: is the portfolio overexposed to any single sector (>25% is a common trigger)?Review geographic concentration: does the portfolio have unintended home bias or EM exposure?Check factor concentration: are you unintentionally tilted toward growth, value, or momentum?Assess correlation risk: in a stress scenario, do the diversifiers actually diversify?Consider liquidity for any holdings that could be hard to exit in a downturn.Review currency exposure for non-GBP holdings — is it hedged, and should it be?

Document Your Monitoring Actions

For each flagged holding, document: (a) the concern, (b) your analysis, (c) the action taken, and (d) the rationale.If you decided NOT to act on a flag, document why. The FCA cares as much about inaction as action.Record any client conversations about portfolio changes — date, summary, and outcome.Generate a dated monitoring brief for the client file. This is your primary evidence of ongoing oversight.If using third-party research, cite the source and date. Don't rely on research older than 90 days.

Maintain the Audit Trail

Save the monitoring brief as PDF with a clear filename: [ClientName]_[Date]_MonitoringBrief.pdfFile the brief where it's accessible for future reviews and potential FCA audit.Maintain a monitoring schedule — quarterly is common, but higher-risk portfolios may warrant monthly.Set a calendar reminder for the next review date. Missed reviews are a red flag.Keep a summary log of monitoring dates, key findings, and actions across all clients.

Check Your Process (Self-Assessment)

Can you demonstrate every client portfolio has been reviewed within the last quarter?If the FCA asked to see your monitoring evidence today, could you produce it within an hour?Are your monitoring records consistent across clients, or do some files have gaps?Do you have a process for escalating serious concerns outside the regular review cycle?Have you reviewed your monitoring process itself in the last 12 months? Consumer Duty expects continuous improvement.

Prepared by Longwalk Research as a practical resource for UK financial advisers. Reflects FCA Consumer Duty expectations as of June 2026. Advisers should consult their compliance professionals for firm-specific requirements.

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