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Working notes.

Field notes from conversations with compliance teams, regulatory primers we wish had existed when we started, and product changes we want you to know about. Below: what we're writing now. We'll publish each as it's ready; the first batch lands ahead of the September 2028 launch.

Annual Reviews
COBS 9.5: What counts as a completed review?
Annual Reviews

COBS 9.5 explained: what counts as a completed annual review in 2026?

Many firms are failing annual reviews that technically happened. Here's the FCA's current standard for what constitutes a completed, evidenced review.

8 May 2026 · 5 min Coming soon
Vulnerable Clients
FG21/1 Update: Proactive vulnerability identification
Vulnerable Clients

The Q2 2025 FG21/1 update: what proactive vulnerability identification actually means

Reactive processes are no longer enough. The updated guidance requires systematic identification at every client touchpoint - here's what that looks like in practice.

1 May 2026 · 6 min Coming soon
RMAR
RMAR 2026: Five Section B data points that trigger FCA attention
RMAR

RMAR 2026: the five Section B data points that trigger FCA supervisory attention

Complaint data inconsistencies and low upheld rates relative to volume are the most common triggers. Here's how to audit your Section B before submission.

24 Apr 2026 · 7 min Coming soon