Building a T&C Scheme for Compliance Confidence
Sector: Wealth Management / IFA Network
Role: Strategic & Compliance Consultant
Service Areas: Governance · People Development · Regulatory Readiness
The Challenge
A growing IFA network was operating with outdated and inconsistent T&C practices. Supervisors were overwhelmed, records were fragmented, and leadership lacked confidence in demonstrating adviser competence.
With increased scrutiny under Consumer Duty and SMCR, the business needed a scalable, defensible approach to competence and oversight.
Our Approach
Bonner-Murray Consulting was engaged to rebuild the T&C framework from the ground up.
The engagement began with a full review of the existing T&C landscape.
This included:
Reviewing training, supervision, and CPD practices
Assessing supervisory workload and role clarity
Identifying gaps in documentation and MI
Understanding cultural and operational constraints.
A new T&C scheme was designed to align FCA expectations with practical delivery.
This involved:
Defining clear supervisory roles and responsibilities
Designing scalable oversight tools
Aligning competence assessment with risk and advice activity
Ensuring proportionality across adviser profiles
Supporting materials and training were developed to embed the framework.
This included:
Supervision templates and competence matrices
MI dashboards to improve leadership visibility
Workshops and 1-to-1 training for supervisors
The Outcome
The network achieved a step change in regulatory confidence.
The outcome included:
A defensible, documented T&C framework
Supervisors equipped with clear tools and expectations
Improved compliance MI and oversight
A confident, supported supervision culture
“It’s the first time we’ve felt confident about how we manage competence and the first time the team’s actually felt supported doing it.”
Head of Compliance (anonymous)
