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Client Segmentation for Estate Planning Services: Who Needs What and When

· 19 min

Executive Summary

The post-April 2025 inheritance tax landscape -- featuring the enacted residence-based regime, nil-rate band freezes through 2029-30, and the confirmed inclusion of pension death benefits within IHT from April 2027 -- has fundamentally altered which clients require estate planning intervention and when. Despite this, industry survey data suggests only 54% of financial advice firms operate a formal client segmentation strategy. The FCA's Consumer Duty (PRIN 2A) now creates an affirmative obligation for firms to define target markets and evidence that service propositions deliver appropriate outcomes by client segment. Assets-under-management-only classification fails to capture total wealth exposure, asset complexity, or life-event triggers that determine estate planning need. This article proposes a five-dimensional segmentation framework grounded in HMRC statistics, ONS wealth data, and FCA regulatory requirements, enabling advisers to map client characteristics to estate planning interventions at the point of greatest impact and demonstrable value.

1. The Regulatory Case for Segmentation

The FCA's Consumer Duty, fully operational since 31 July 2024, imposes obligations that extend well beyond product governance into the design and delivery of advisory services. Under PRIN 2A.4, firms must define the target market for each product or service, identify groups for whom the offering is not suitable, and monitor outcomes across client segments to ensure the Duty's four outcomes -- products and services, price and value, consumer understanding, and consumer support -- are being met.1 For estate planning services, this means advisory firms must articulate, in documented form, which client populations require estate planning advice, what level of service each segment receives, and how outcomes are measured across those segments.

The distinction between FCA client categorisation under COBS 3 and internal service segmentation is critical. Client categorisation is a regulatory classification determining the level of protection afforded to each client -- retail, professional, or eligible counterparty. Service segmentation, by contrast, is a practice management tool determining the scope, frequency, and depth of advisory engagement. The two frameworks operate in parallel but serve different purposes. The FCA's December 2025 consultation paper CP25/36 proposes amendments to COBS 3 client categorisation rules, including a new wealth-based route for elective professional client status at a minimum of 10 million pounds in investable assets, and streamlined reassessment obligations.2 While these proposals remain at consultation stage (responses closed 2 February 2026), they signal the regulator's recognition that client classification frameworks require modernisation.3

The FCA's Financial Lives 2024 survey underscores the scale of the advisory gap that effective segmentation could address. Only 9% of UK adults received financial advice in the prior 12 months, while an estimated 7 million adults with 10,000 pounds or more in savings may be missing out on investment benefits.4 Of those with savings who do not invest, 24% cited insufficient knowledge and 12% felt overwhelmed by options -- barriers that structured segmentation and tiered service propositions are well placed to address. For estate planning specifically, the combination of rising asset values, frozen IHT thresholds, and forthcoming pension inclusion means the population with a legitimate need for estate planning advice is expanding materially beyond those currently receiving it.

The FCA's multi-firm review of client categorisation in corporate finance and investment management firms, published in October 2025, identified superficial assessments, invalid criteria, and weak documentation as recurring deficiencies.3 While that review focused on client categorisation rather than service segmentation, its findings carry direct implications: firms that cannot evidence robust client classification are unlikely to demonstrate robust service differentiation either. The Consumer Duty's emphasis on evidenced outcomes makes a documented segmentation framework both a compliance tool and a quality assurance mechanism. Industry survey data suggests momentum is building: the Managing Lifetime Wealth 2024 report found that 54% of financial advisers already segment their client base, with a further 10% expecting to begin doing so, driven principally by Consumer Duty implementation requirements.5

2. The Inheritance Tax Landscape as Segmentation Driver

The IHT reform programme enacted since 2024 has created distinct client cohorts with materially different planning needs, rendering any single-tier or AUM-only segmentation model inadequate.

Frozen Nil-Rate Bands and Fiscal Drag

The nil-rate band remains fixed at 325,000 pounds and the residence nil-rate band at 175,000 pounds through 2029-30, with the taper threshold unchanged at 2 million pounds.6 While the government forecasts that more than 93% of estates will have no IHT liability in each of the next five years, the number of liable estates continues to grow: 31,500 estates were IHT-liable in 2022-23 with aggregate liabilities of 6.70 billion pounds, representing year-on-year increases of 13% and 12% respectively.78 The fiscal drag effect -- rising asset values against static thresholds -- is the principal mechanism drawing additional estates into IHT scope. ONS data shows median household wealth in Great Britain at 293,700 pounds (April 2020 to March 2022), with the wealthiest 10% holding 1,200,500 pounds or more.9 Net property wealth comprises 40% and private pension wealth 35% of household totals, meaning that for a substantial proportion of households, the two largest wealth components sit outside the assets typically captured by AUM-based segmentation. As median wealth approaches the NRB, a growing proportion of households that would not historically have considered themselves "wealthy" are acquiring IHT exposure.

Pension Death Benefits from April 2027

The confirmed inclusion of most unused pension funds and death benefits within IHT from 6 April 2027 represents the single most significant change to the estate planning landscape for the adviser community.10 Personal representatives, not pension scheme administrators, will be liable for reporting and payment. Government impact assessments estimate that 10,500 estates will become newly IHT-liable and 38,500 estates will pay more IHT as a result, with an average liability increase of approximately 34,000 pounds per affected estate.11 Exclusions apply to death-in-service benefits from registered pension schemes and dependant's scheme pensions from defined benefit arrangements.10

For segmentation purposes, the pension inclusion creates a new client cohort: individuals whose estates fall below the IHT threshold on current rules but whose combined pension and non-pension wealth will exceed it from April 2027. Identifying these clients proactively -- rather than reactively upon death -- requires advisers to assess total wealth across pension and non-pension assets, a calculation that AUM-based segmentation cannot perform. The technical consultation response published in July 2025 confirmed the reporting framework, making the operational requirements for advisers increasingly concrete.10

The Residence-Based IHT Regime

The replacement of the domicile-based system with a residence-based regime from 6 April 2025 introduces a fundamentally different test for determining which individuals are within IHT scope for their worldwide assets.12 A long-term UK resident is defined as an individual who has been UK resident for at least 10 out of the last 20 tax years preceding the chargeable event. Tail provisions ensure that long-term residents who leave the UK remain within IHT scope for a minimum of 3 tax years after departure, increasing by one year for each additional year of prior residence, up to a maximum of 10 years. The clock resets only after 10 consecutive years of non-residence.13

This regime creates a distinct segmentation dimension: internationally mobile clients -- including those who have relocated to the UK, those planning to leave, and those with assets across multiple jurisdictions -- now require specialist assessment against the long-term residence test that was not necessary under the domicile-based system. Trust property settled by a long-term UK resident is also within IHT scope, with a cap of 5 million pounds on relevant property charges applying to trusts holding excluded property at 30 October 2024.12

Agricultural Property Relief and Business Property Relief Reforms

The combined allowance for the 100% rate of APR and BPR, announced at 1 million pounds in the Autumn Budget 2024 and subsequently increased to 2.5 million pounds in December 2025, takes effect from April 2026.14 Spouses or civil partners can pass on up to 5 million pounds in qualifying agricultural or business assets (2 x 2.5 million pounds) before IHT applies on those assets; combined with nil-rate bands, the total tax-free transfer between spouses reaches up to 5.65 million pounds.14 Business owners and agricultural landholders therefore constitute a segment requiring specialist advice on the interaction between these allowances, succession planning, and the wider IHT framework. The scale of the change -- from unlimited 100% relief to a capped allowance -- represents a fundamental shift in the estate planning calculus for business and agricultural clients.

3. A Multi-Dimensional Segmentation Framework

Traditional AUM-based tiering captures only one dimension of a client's estate planning need. A segmentation model fit for the post-2025 IHT landscape and Consumer Duty obligations requires assessment across five dimensions, each of which independently generates planning needs that AUM alone cannot identify.

Dimension 1: Total Wealth Tier

The first dimension extends beyond assets under management to encompass total household wealth, including property, pension wealth, business interests, and assets held with other providers. Using ONS Wealth and Assets Survey data and IHT thresholds as anchor points, five tiers can be defined:96

  • Tier 1 (Sub-NRB): Total wealth below 325,000 pounds. Typically no IHT exposure; estate planning needs centre on will preparation, lasting powers of attorney, and pension nomination accuracy.
  • Tier 2 (NRB to RNRB zone): Total wealth between 325,000 and 1,000,000 pounds. Potential IHT exposure mitigated by RNRB if conditions are met; planning focus on RNRB qualification and pension nomination review ahead of April 2027.
  • Tier 3 (RNRB to taper): Total wealth between 1,000,000 and 2,000,000 pounds. IHT exposure likely; lifetime gifting strategies, trust planning, and pension drawdown sequencing become relevant.
  • Tier 4 (Above taper): Total wealth exceeding 2,000,000 pounds. RNRB tapers to nil; comprehensive estate planning review required, including inter-vivos gifting, trust structures, and charitable giving strategies.
  • Tier 5 (Ultra-high-net-worth): Total wealth exceeding 10,000,000 pounds. Multi-generational planning, cross-border considerations, and specialist tax advice typically required. This threshold aligns with the proposed CP25/36 elective professional client classification.2

The critical distinction from AUM-based models is the inclusion of pension wealth. A client with 400,000 pounds in investable assets and 350,000 pounds in pension funds has a combined estate of 750,000 pounds -- comfortably within Tier 2 on total wealth, but potentially classified as a lower-priority client under AUM-only segmentation. From April 2027, the pension component becomes directly relevant to IHT liability.11

Dimension 2: Asset Complexity

Asset complexity determines the sophistication and cost of the planning required:

  • Standard: Cash savings, listed investments, primary residence, defined contribution pensions. Planning interventions are relatively standardised.
  • Moderate: Multiple properties, ISA portfolios, multiple pension arrangements, buy-to-let holdings. Requires coordination across asset classes and tax wrappers.
  • Complex: Business interests qualifying for BPR, agricultural property qualifying for APR, trust structures, overseas assets, carried interest, or share option schemes. Requires specialist advice and typically multi-disciplinary coordination with solicitors, tax advisers, and accountants.14

Dimension 3: Family Structure

Family structure is among the most significant determinants of estate planning complexity, yet it is frequently absent from segmentation models:

  • Single or unmarried individuals: No spousal exemption; full NRB utilisation is the primary planning tool.
  • Married couples or civil partners (first relationship): Spousal exemption and transferable NRB/RNRB provide substantial IHT mitigation; planning focuses on will structures that optimise allowance utilisation.
  • Blended families: Competing interests between current spouse/partner and children from prior relationships create significant will drafting complexity, including life interest trusts and discretionary arrangements.
  • Cohabiting couples: No spousal exemption or automatic inheritance rights under intestacy; estate planning is essential rather than advisable.
  • Families with vulnerable beneficiaries: Discretionary trusts, disabled person's trusts, and coordination with means-tested benefits require specialist planning.

Dimension 4: Life Stage and Trigger Events

Static wealth thresholds fail to capture the dynamic nature of estate planning need. Life events create natural engagement points where the value of proactive advice is highest:7

  • Accumulation phase (25-45): Will preparation, pension nomination, life insurance adequacy. The FCA's Consumer Duty requires firms to consider foreseeable harm, including the consequences of intestacy for young families.
  • Pre-retirement (45-60): Pension consolidation review, total wealth assessment against IHT thresholds, lifetime gifting strategy initiation (seven-year rule), business succession planning.
  • Decumulation (60-75): Pension drawdown sequencing with IHT implications (particularly pre-April 2027), downsizing and RNRB retention, review of existing trust structures.
  • Later life (75+): Capacity planning, LPA execution, will review for changed circumstances, pre-death planning including charitable legacies and deed of variation awareness. HMRC data confirms that 79% of IHT is paid by estates of individuals aged 75 or over, with slightly more women's estates (51%) than men's (49%).7
  • Intergenerational transfer: Receipt of inheritance (those aged 55-64 are statistically most likely to inherit and receive the largest average inheritances), business succession, and gift-with-reservation-of-benefit considerations.9

Dimension 5: Regulatory Exposure

The final dimension captures differential regulatory complexity that requires segment-specific expertise:

  • UK-only: Standard IHT rules apply; planning within a single jurisdiction.
  • Cross-border (residence-based regime): Clients subject to the long-term UK residence test, including those with overseas domicile of origin, those planning international relocation, and those with assets in multiple jurisdictions. The tail provisions require ongoing monitoring of residence status for up to 10 years after departure.1213
  • Business owners (APR/BPR): The reformed allowance structure from April 2026 requires specialist advice on qualifying conditions, interaction with the NRB, and succession planning for business and agricultural assets.14
  • Pension wealth holders: Clients whose pension funds constitute a material proportion of total wealth face a step change in estate planning requirements from April 2027. Proactive identification of this cohort is commercially significant.10

4. Mapping Segments to Service Propositions

The five-dimensional framework generates a matrix of client profiles, each with identifiable planning needs. For practical implementation, these profiles can be consolidated into three service tiers, each with defined scope, frequency, and Consumer Duty evidencing requirements.

Tier A: Comprehensive Estate Planning

Profile: Tier 4-5 total wealth, complex assets, blended family structures or cross-border exposure, decumulation or later-life stage.

Service proposition: Full estate planning review incorporating IHT mitigation strategy, trust and will coordination, pension drawdown sequencing, cross-disciplinary referral to solicitors and tax advisers, and annual review cycle. This tier typically involves bespoke cashflow modelling and scenario analysis. The FCA's thematic review of retirement income advice (TR24/1) found that 67% of reviewed files were suitable but 22% had material information gaps, with inconsistent use of cashflow modelling identified as a recurring weakness.15 Firms serving Tier A clients must ensure that estate planning is integrated with retirement income strategy, not treated as a separate workstream. The 11% of files that raised suitability concerns underscore the importance of documented reasoning that connects the estate planning recommendation to the client's specific circumstances across all five segmentation dimensions.15

Consumer Duty evidencing: Documented target market definition, individual outcome assessment at each annual review, and evidence that cross-disciplinary coordination has been facilitated where asset complexity requires it.

Tier B: Focused Estate Planning

Profile: Tier 2-3 total wealth, moderate asset complexity, first-marriage couples or cohabiting partners, pre-retirement or early decumulation stage.

Service proposition: Focused IHT exposure assessment, pension nomination review (priority action ahead of April 2027), RNRB qualification check, basic lifetime gifting strategy, and referral for will and LPA preparation. Biannual review cycle aligned to key trigger events. For clients with pension wealth that brings total estate above the NRB, the April 2027 change is the most time-sensitive planning trigger. Regional variation adds nuance: ONS data shows median household wealth in the South East at 489,800 pounds compared with 179,900 pounds in the North East, meaning the proportion of Tier 2 and Tier 3 clients varies significantly by practice geography.9

Consumer Duty evidencing: Segment-level outcome monitoring (proportion of clients with current wills, pension nominations reviewed, IHT exposure assessed), documented service scope so that clients understand what is and is not included.

Tier C: Awareness and Referral

Profile: Tier 1 total wealth, standard asset complexity, single or married without dependants, accumulation stage.

Service proposition: Educational content on estate planning fundamentals, will and LPA referral to appropriate providers, pension nomination accuracy check, and automated trigger-based re-engagement when life events or wealth accumulation warrant reassessment. Digital service delivery and scalable communication tools are appropriate for this tier.

Consumer Duty evidencing: Evidence that the firm has considered and documented why comprehensive estate planning is not appropriate for this segment, and that mechanisms exist to identify clients who transition to a higher tier through wealth accumulation or life events.

The FCA's multi-firm review of consolidation in the financial advice and wealth management sector highlighted that fast growth through acquisition can disrupt service delivery and client segmentation.16 Some evidence of high debt levels, limited stress testing, and short-term refinancing strategies was found among consolidating firms. Firms undergoing or contemplating acquisition should ensure that segmentation frameworks survive integration, with particular attention to migrating client data across CRM systems and reconciling different service tier definitions.

5. Implementation and Operational Considerations

Data Architecture

Effective segmentation requires CRM systems capable of capturing all five dimensions. At minimum, advisers need fields for total household wealth (not just AUM), pension fund values across all schemes, property holdings, business interests, family structure, nationality and residence history, and life-event flags. The pension inclusion from April 2027 makes pension fund visibility a non-negotiable data requirement; firms that cannot aggregate a client's pension wealth across multiple schemes cannot assess IHT exposure accurately.11

Technology Enablers

Automated trigger alerts represent the highest-value technology investment for segmentation-driven estate planning. Systems that flag when a client reaches a wealth threshold, reports a life event, or approaches a regulatory trigger date (such as the April 2027 pension inclusion) enable proactive engagement rather than reactive response. Segmentation dashboards that present the adviser book by tier, with outcome metrics by segment, support both Consumer Duty evidencing and management information reporting.1

Capacity Planning and Revenue Capture

Segmentation enables rational allocation of adviser time. Tier A clients warrant senior adviser engagement and multi-disciplinary coordination; Tier B clients can be served efficiently through structured review processes; Tier C clients can be supported through scalable digital channels and referral pathways. The concentration effect identified in practice management research -- where a minority of clients generate the majority of revenue -- is not an argument for ignoring lower tiers, but for serving them efficiently through appropriate channels. Industry survey data illustrates this concentration in quantitative terms: one firm reported that 94% of annual revenue was generated by 40% of its client base, a distribution consistent with the Pareto principle widely observed in financial advice businesses.5

The commercial opportunity is material. With 31,500 estates already IHT-liable and the pension inclusion expected to bring a further 10,500 into scope, the addressable market for estate planning advice is growing against a backdrop where only 9% of adults currently access financial advice.74 Firms that can identify estate planning need proactively through structured segmentation are better positioned to capture this demand.

Common Pitfalls

Three implementation failures recur in practice. First, AUM-only classification, which misses pension wealth, property equity, and business interests that collectively determine IHT exposure. Second, static models that are set at onboarding and never revisited, missing life events and wealth accumulation that shift clients between tiers. Third, service creep, where the absence of documented service scope for each tier results in inconsistent delivery and undermines Consumer Duty evidencing. A fourth, related risk arises in firms pursuing growth through acquisition: inherited client books may use incompatible segmentation criteria, and failure to reconcile these during integration can leave substantial numbers of clients in inappropriate service tiers.16

Conclusion

The convergence of the post-2025 IHT reform programme and the FCA's Consumer Duty has transformed client segmentation from a discretionary practice management exercise into a regulatory expectation and commercial imperative. The residence-based IHT regime, frozen nil-rate bands through 2029-30, the confirmed pension inclusion from April 2027, and APR/BPR reforms from April 2026 have collectively expanded and diversified the population requiring estate planning advice. A multi-dimensional segmentation framework -- incorporating total wealth, asset complexity, family structure, life stage, and regulatory exposure -- enables advisers to identify which clients need estate planning intervention, determine what level of service is appropriate, and deliver that service at the point of greatest impact.

The most immediate action for advisory firms is a review of pension wealth exposure across the client book ahead of the April 2027 inclusion. Clients whose combined pension and non-pension wealth exceeds the NRB, but who are not currently receiving estate planning advice, represent both a regulatory risk under the Consumer Duty's foreseeable harm provisions and a significant revenue opportunity. Structured segmentation is the mechanism that transforms this challenge from an abstract concern into an actionable client engagement programme.

CPD Declaration

Estimated Reading Time: 18 minutes Technical Level: Advanced Practice Areas: Estate Planning, IHT Advisory, Client Relationship Management, Regulatory Compliance

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Evaluate the limitations of AUM-based client segmentation for estate planning services in the context of the post-2025 IHT reform landscape
  2. Apply the five-dimensional segmentation framework (total wealth, asset complexity, family structure, life stage, regulatory exposure) to classify existing client populations by estate planning need
  3. Analyse the impact of the April 2027 pension death benefit inclusion on client segment boundaries and identify clients requiring proactive reassessment
  4. Design service propositions for differentiated client tiers that satisfy Consumer Duty target market and outcome evidencing requirements under PRIN 2A

FCA Competency Mapping

  • Maintaining competence in investment and estate planning advice (TC 2.1)
  • Applying regulatory requirements to service design and delivery (PRIN 2A, Consumer Duty)
  • Evidencing suitability and target market assessment across client segments (COBS 9, PROD 3)

Reflective Questions

  1. How would you assess the proportion of your client book whose total wealth (including pension funds) exceeds the nil-rate band, and what data gaps would need to be addressed to perform this analysis?
  2. What changes to your firm's CRM system and review processes would be required to implement life-event trigger-based segmentation rather than static AUM tiering?
  3. How does your current service proposition documentation demonstrate to the FCA that estate planning advice is being delivered to the appropriate target market, and where are the evidencing gaps?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-02-04. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. FCA, "Our Consumer Duty focus areas." https://www.fca.org.uk/publications/corporate-documents/consumer-duty-focus-areas ↩ ↩2

  2. FCA, "CP25/36: Client categorisation and conflicts of interest" (8 December 2025). https://www.fca.org.uk/publications/consultation-papers/cp25-36-client-categorisation-conflicts-interest ↩ ↩2

  3. FCA, "Multi-firm review of client categorisation in corporate finance firms: high-level observations" (October 2025). https://www.fca.org.uk/publications/multi-firm-reviews/multi-firm-review-client-categorisation-corporate-finance-firms-high-level-observations ↩ ↩2

  4. FCA, "Financial Lives 2024 survey." https://www.fca.org.uk/financial-lives/financial-lives-2024 ↩ ↩2

  5. Professional Adviser, "Client segmentation expected to grow among advice firms" (Managing Lifetime Wealth 2024 report). https://www.professionaladviser.com/news/4171946/client-segmentation-expected-grow-advice-firms ↩ ↩2

  6. GOV.UK, "Inheritance Tax nil-rate band and residence nil-rate band thresholds from 6 April 2026 to 5 April 2028." https://www.gov.uk/government/publications/inheritance-tax-nil-rate-band-and-residence-nil-rate-band-thresholds-from-6-april-2026/inheritance-tax-nil-rate-band-and-residence-nil-rate-band-thresholds-from-6-april-2026-to-5-april-2028 ↩ ↩2

  7. HMRC, "Inheritance Tax liabilities statistics: commentary." https://www.gov.uk/government/statistics/inheritance-tax-liabilities-statistics/inheritance-tax-liabilities-statistics-commentary ↩ ↩2 ↩3 ↩4

  8. GOV.UK, "Inheritance Tax nil-rate band and residence nil-rate band thresholds from 6 April 2028." https://www.gov.uk/government/publications/inheritance-tax-nil-rate-band-and-residence-nil-rate-bands-from-6-april-2028/inheritance-tax-nil-rate-band-residence-nil-rate-band-from-6-april-2028 ↩

  9. ONS, "Household total wealth in Great Britain: April 2020 to March 2022." https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances/incomeandwealth/bulletins/totalwealthingreatbritain/april2020tomarch2022 ↩ ↩2 ↩3 ↩4

  10. GOV.UK, "Inheritance Tax -- unused pension funds and death benefits." https://www.gov.uk/government/publications/inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-unused-pension-funds-and-death-benefits ↩ ↩2 ↩3 ↩4

  11. GOV.UK, "Reforming Inheritance Tax: unused pension funds and death benefits." https://www.gov.uk/government/publications/reforming-inheritance-tax-unused-pension-funds-and-death-benefits/inheritance-tax-on-unused-pension-funds-and-death-benefits ↩ ↩2 ↩3

  12. GOV.UK, "Inheritance Tax if you're a long-term UK resident" (6 April 2025). https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident ↩ ↩2 ↩3

  13. HMRC, "Inheritance Tax Manual -- Long-term UK residence test (IHTM47020)." https://www.gov.uk/hmrc-internal-manuals/inheritance-tax-manual/ihtm47020 ↩ ↩2

  14. GOV.UK, "Agricultural property relief and business property relief changes" (23 December 2025). https://www.gov.uk/government/publications/changes-to-agricultural-property-relief-and-business-property-relief/agricultural-property-relief-and-business-property-relief-changes ↩ ↩2 ↩3 ↩4

  15. FCA, "Retirement income advice: good practice and areas for improvement." https://www.fca.org.uk/publications/good-and-poor-practice/retirement-income-advice-good-practice-areas-improvement ↩ ↩2

  16. FCA, "Multi-firm review of consolidation in the financial advice and wealth management sector" (October 2025). https://www.fca.org.uk/publications/multi-firm-reviews/consolidation-financial-advice-and-wealth-management-sector ↩ ↩2

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