FCA supervisory case studies: lessons from recent interventions
The FCA publishes supervisory case studies and good practice examples across its thematic reviews, finalised guidance, and Dear CEO letters. Reading these publications carefully — rather than simply extracting the headline obligations — provides some of the most reliable guidance available on what the regulator actually expects and what it considers inadequate. The following analysis draws on case study material published by the FCA in 2023 and 2024 across four sectors: consumer credit, asset management, insurance, and retail banking. The pattern across all four sectors is consistent: firms that treat compliance as a documentation exercise rather than a genuine risk management tool are repeatedly and predictably identified as falling short.
In consumer credit, the FCA's supervisory work has focused on affordability assessment and treatment of customers in financial difficulty. Case studies from its supervisory engagement with consumer credit firms show that affordability assessments conducted at origination frequently relied on income declarations without adequate verification, and that repayment plans for customers in arrears were set at levels that created or extended financial difficulty rather than addressing it. The FCA identified firms in which collections staff had targets for repayment plan amounts that systematically overrode the customer's actual capacity to repay — a conduct issue that the regulator treated as a systemic control failure rather than a series of individual adviser errors.
In asset management, the FCA's supervisory engagement has generated case studies around portfolio management conflicts, the quality of best execution monitoring, and the adequacy of governance around liquidity risk. One published case study describes an asset manager that maintained a written best execution policy which was not implemented in its actual trade routing decisions — the difference between policy and practice was identified through data analysis of actual trade execution quality, not through compliance self-assessment. This illustrates a broader supervisory methodology: the FCA increasingly uses its own data capabilities to test whether firms' compliance positions are reflected in actual behaviours.
In insurance, case studies from the FCA's Consumer Duty reviews document firms that had invested significantly in Consumer Duty documentation — policy statements, target market assessments, value assessments — but where the documentation was not integrated into actual product design, pricing, or distribution decisions. The FCA's supervisory teams found that product and pricing decisions continued to be made without reference to the Consumer Duty framework, and that the Consumer Duty documents were being produced as a separate compliance exercise rather than as the output of a genuine governance process. This disconnect between documentation and practice is consistently identified as a hallmark of inadequate compliance.
Cross-cutting lessons
The cross-cutting lessons from the FCA's published case studies are consistent: the regulator values genuine governance over documentary compliance; it uses data to test stated positions against actual behaviours; it expects senior management to be actively involved in identifying and remediating issues, not merely approving them after the fact; and it treats a pattern of repeated failures in the same area as evidence of inadequate culture rather than unlucky coincidence. Firms should read supervisory case studies not as information about other firms' mistakes, but as a mirror in which to examine their own compliance arrangements.