Welcome to The Week That Was, a round-up of key events in the financial services sector over the last seven days.
The fifth episode of Season 4 of our podcast, Money Covered – The Month That Was, where the team looks at the Financial Conduct Authority's Vehicle Finance Redress Scheme Consultation, is now available.
To listen to this and all previous episodes, please click here.
Headline development
FCA flags resilience investment challenges and access-to-finance frictions following joint scenario testing with the MoD
On 7 September, the FCA published findings from work with the Ministry of Defence to test firms’ resilience to challenging scenarios, including a cyber-attack on a cable landing station and regional Global Navigation Satellite System spoofing. Around 120 leaders from financial services, government and defence took part in a Defence, Security and Resilience Lab exploring how hostile activity, supply chain disruption and dual use technologies can affect market integrity and UK security, with a focus on systemic risks and resilience investment opportunities (rather than firm-level exercises).
The FCA identified gaps in system level thinking, including multiple shared dependencies and difficulties in pinpointing where resilience investment is most needed and how to measure its value.
Next steps include further work on supporting intelligence sharing, considering “fail safe” back-up technologies, and exploring access to banking/finance frictions. The FCA notes the webpage is not FCA/government regulatory guidance.
To read more please click here.
Regulatory developments for FCA regulated entities
FCA gives update on simplified advice
On 8 September 2026, Kate Tuckley, head of department for consumer investments at the Financial Conduct Authority (FCA) gave a speech at Verve’s Transformation 2026 conference which included an update on simplified advice.
Tuckley confirmed that the FCA is set to publish its final rules on simplified advice by the end of the year. The FCA launched its simplified advice consultation last March, and this closed in May. The aim of simplified advice is to create a stronger investment culture and to improve confidence about investing for consumers and to improve financial literacy. The key features of the FCA's proposals include consolidation of the suitability framework and streamlining documentation.
Tuckley also added that the FCA's model portfolio services (MPS) review findings should be released at the start of 2027. The FCA conducted the multi-firm review to assess Consumer Duty compliance, fair value assessments, governance, risk controls, and distribution chain information.
To read more about simplified advice, please click here.
Relevant case law updates
High Court finds firm did not breach requirements on vulnerability or appropriateness
In Mark Grogan v IG Index Ltd [2026] EWHC 1998 (Ch), the High Court dismissed a retail client’s claim seeking to recover over £1m of spread betting losses on the basis of (1) alleged breaches of Chapter 10A of the Financial Conduct Authority's (FCA) Conduct of Business Sourcebook (COBS) regarding appropriateness and (2) failure to identify vulnerability and breach of the COBS 2.1.1 “best interests” rule. The Claimant used the online trading platform to carry out spread betting. This is a form of trading unique to the UK, where traders speculate on markets (for example currencies or shares) and trade on the financial price movements without owning the underlying asset, using leverage. Spread betting is subject to FCA regulation.
The Court held that IG Index had not breached the initial appropriateness requirements: the Claimant’s quiz answers and wider evidence showed he understood the risks, and compulsive behaviour (which was the Claimant's problem) is not what the appropriateness assessment is designed to test. Following Quinn v IG Index and Day v Forex, the Court rejected any ongoing duty to reassess appropriateness as trading continued. On vulnerability, applying the autonomy-focused approach in Calvert v William Hill, the Claimant failed to show material from which IG Index knew or ought reasonably to have inferred a gambling disorder or other vulnerability; absent that knowledge, the best interests claim under COBS 2.1.1 also could not succeed.
The practical takeaway from this decision is that firms are not generally required to conduct rolling appropriateness assessments, but should ensure robust processes for identifying and responding where vulnerability is actually apparent (or ought to be apparent) on the information available.
To read the decision, please click here.
With thanks to this week's contributors: Lauren Butler, Daniel Parkin and Brendan Marrian.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
