FCA survey of corporate finance firms - what PE and VC teams should act on

Why this matters

The FCA’s latest review of corporate finance firms highlights recurring weaknesses in controls that are highly relevant to PE and VC managers who run corporate finance permissions or advisory activities. The themes map directly to financial promotions, client categorisation, conflicts, market abuse controls and record-keeping. Treat this as a practical checklist to harden your operating model.

Key themes from the survey

• Financial promotions discipline
  Firms must evidence clear approvals, prominent risk warnings and channel consistency. Materials should align with target-market definitions and Consumer Duty standards.

• Client categorisation and suitability
  Processes for elective professional and high net worth status require documented tests, periodic refresh and controls against self-certification drift.

• Conflicts of interest
  Identification, registration and mitigation plans need to be specific to mandates, including wall-crossing, gift and hospitality thresholds and disclosure language.

• Market abuse controls
  Insider lists, wall-crossing procedures, restricted lists, surveillance triggers and personal account dealing oversight should be fully operational and reviewed.

• Record-keeping and evidence
  Versioned documents, approvals, rationale notes and timed attestations are essential. Email trails alone are not enough.

What good looks like

• A promotions register with approver, date, audience, channel, risk wording and expiry.

• A categorisation pack that stores test evidence, reviewer sign-off and the date of next review.

• A conflicts register linked to mandates, with owner, mitigation and client disclosure references.

• A market abuse playbook covering insider list templates, surveillance exceptions, PA dealing approvals and breach handling.

• A single evidence vault that can produce audit-ready packs in minutes.

Controls to implement now

• Pre-approval workflow for all promotions with mandatory fields and risk checks

• Categorisation tests embedded in onboarding and refreshed to a set cadence

• Mandate-specific conflicts mapping with automatic disclosure templates

• Insider and restricted list tooling with monitored wall-crossing steps

• Policy versioning and change logs with approver IDs and timestamps

60-day action plan

1. Week 1 to 2
   Gap-assess promotions, categorisation, conflicts, market abuse and records.

2. Week 3 to 4
   Stand up a promotions register and evidence vault. Refresh categorisation tests.

3. Week 5 to 6
   Implement insider list management and PA dealing oversight. Run a breach simulation.

4. Week 7 to 8
   Train teams, update playbooks, and run an internal audit dry run.

KPIs to track

• Time to produce a complete evidence pack

• Percentage of promotions with full approvals and correct warnings

• Categorisation refresh completion rate

• Insider list accuracy and wall-crossing timeliness

• Number of surveillance exceptions resolved inside SLA

Takeaway

This is an operations exercise with compliance outcomes. Build approvals, categorisation, conflicts and market abuse controls into the workflow, keep a single evidence source and monitor KPIs. The result is speed with control and cleaner regulatory outcomes.