Personalised support without regulatory overstep: a new opportunity for retail finance

The FCA’s Advice Guidance Boundary Review, while centred on pensions and investments, signals a broader shift in the regulator’s thinking — and one that has real implications for firms operating in retail, motor, green energy, and sports finance.

At its core, the review tackles a familiar challenge: how can firms support consumers with financial decisions in a way that is clear, personalised and compliant — particularly when those consumers may be vulnerable?

The relevance beyond investments

While the proposals are designed to make investment advice more accessible, the underlying message from the FCA is more universal. Consumers need help navigating financial decisions. Firms want to help but often hold back for fear of regulatory overstep. The current framework doesn’t always reflect the reality of everyday financial decisions.
These challenges are just as present, and often more pressing, in sectors such as:

Retail credit (for furniture, appliances or electronics)
Motor finance
Green energy finance (solar panels, heat pumps)
Season ticket finance or supporter schemes

These are affordability decisions as much as product choices. They often involve customers facing financial pressure or change — where timely, appropriate support can make a significant difference.

Consumer vulnerability: the real intersection

The FCA has made it clear that vulnerability remains a top regulatory priority. Under Consumer Duty, firms must not only avoid harm but proactively deliver fair treatment and good outcomes.

Whether someone is experiencing financial stress, variable income, or life events affecting their ability to manage credit, they may require help to understand and assess their options. But offering that help must stay within the rules.

The review points towards a future where firms could offer more tailored guidance — not only in wealth management, but in any regulated sector where financial decisions affect day-to-day life.

What this means for your firm

At Product Partnerships, we are working with clients to assess what this means in practical terms:

Where in your journey are customers looking for help, but only receiving generic information?
Could staff unintentionally cross the boundary into advice?
How are vulnerable customers supported at key decision points?
Do your scripts, digital journeys, and disclosures reflect the level of support you intend to give?

The FCA's review complements the expectations already outlined in the Consumer Duty, especially around customer understanding and support.

Our view: don’t wait for formal reform

The regulatory framework may take time to change, but the direction is clear — and firms can act now.
Practical steps include:

Offering clearer, simpler guidance tools and signposting
Training staff to recognise and respond to vulnerability appropriately
Putting guardrails in place to avoid drifting into advice
Reviewing customer journeys through a compliance and vulnerability lens

We’re already supporting firms in adapting their compliance strategies to meet today’s standards — while anticipating what’s coming next.

Final thoughts

The FCA’s review is more than a technical paper on investment advice. It’s a signal that expectations around customer support are evolving — across all areas of financial services.

For firms in retail finance, motor, energy, sport, and others, now is the time to review how you engage with your customers, especially those in vulnerable situations. Future compliance depends on action today.

What the FCA’s Advice Review Means for Retail Finance – and Why It Matters for Vulnerability