Fair value assessment and Consumer Duty when you buy leads
An introducer due-diligence checklist for compliance officers and principals: what the FCA expects, how to evidence target market, and which fee models hold up.
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This is a practical checklist written by a company that sells pension appointments, not legal or compliance advice. Rules are quoted from the FCA Handbook and FCA publications as they stood on 27 September 2026. Your compliance function, network or consultant has the final say for your firm. InvestmentsBooked is not authorised by the FCA and does not give financial advice.
This one is written for compliance officers and principals rather than for the adviser who wants more meetings. For a small firm, much of Consumer Duty comes down to evidence: keeping a record that you've checked things, including things you don't directly control. Bought-in clients are one of those things. The supplier might be unregulated, you might never see their adverts, and yet the client who turns up in your diary is your responsibility from the first minute.
What follows is what the rules say, a checklist you can lift into your introducer file, and the questions we'd ask any supplier (including us).
What is a fair value assessment under Consumer Duty?
It's the price and value outcome, written down. Under PRIN 2A.4, a firm that manufactures a product or service must assess whether it gives fair value to its target market before it's offered, and review that regularly. Fair value means the total price the customer pays is reasonable relative to the benefits they can reasonably expect.
PRIN 2A.4.8R lists what the assessment has to weigh:
- the nature of the product or service, including the benefits it gives and its quality
- any limitations that are part of it
- the expected total price, including initial, ongoing and contingent charges, and non-financial costs (the FCA's guidance gives handing over personal data as an example of one)
- whether characteristics of vulnerability in the target market make fair value less likely for some customers
For an advice firm, the thing being assessed is usually your own service: the initial advice, the ongoing service and what each costs. Distributors have a separate duty in PRIN 2A.4.16R: get enough information to understand the manufacturer's assessment, don't distribute where your own arrangements would stop the product giving fair value, and consider how your services and remuneration affect value.
The FCA has been blunt about what goes wrong. When it reviewed 14 firms' fair value frameworks in May 2023, it found weak plans for outcome data, averages that hid poor outcomes for some groups, and too little thought about information needed from others in the distribution chain. Its February 2024 examples added unjustified remuneration, fees stacking up through a chain, and customers paying for services they didn't receive. In the advice sector specifically, its 2025 review of ongoing advice at 22 large firms found about 83% of promised reviews were delivered, 15% were declined or not engaged with by clients, and under 2% had no attempt at all. That last group is the one the FCA said would likely need redress.
None of that mentions leads. Which is the gap this article is about.
Where does a lead or appointment fee sit in your fair value assessment?
A client never sees your lead bill. It isn't a customer charge, so it doesn't go in the "total price" column, and no rule says every assessment needs a separate lead-cost line. But it's worth considering and documenting, for three reasons.
- It can affect what clients pay. Acquisition cost is a cost of serving clients. Whether you absorb it in margin or it feeds into the charges you set is your decision, but if a channel were so expensive that fees had to rise to pay for it, that would be a value question.
- It can shape behaviour. A supplier paid per sale, or on a share of assets, has an interest in what the client ends up doing. So can an adviser who's paid heavily for a lead and feels the need to close it. The Duty's cross-cutting rules (act in good faith, avoid foreseeable harm, support customers' objectives) are about exactly that kind of pressure.
- It sets your target market in practice. Whoever writes the adverts and the qualifier decides who arrives. If that isn't your target market, your fair value assessment is describing clients you don't have.
A simple way to put it in the file is cost per client acquired, by channel. For a flat per-meeting fee that's easy to calculate:
Cost per new client = fee per attended meeting ÷ proportion of meetings that become clients
At £500 per show, a 25% show-to-client rate gives £2,000 per client; 10% gives £5,000; 40% gives £1,250. Those rates are illustrative, not a forecast, and yours will depend on your fees, your proposition and how quickly you follow up. The point for the value file is that the number is knowable and stable, which is harder to say for a subscription plus per-enquiry model where half the enquiries never answer.
Can you hand Consumer Duty responsibility to a lead supplier?
No, and the FCA has said so in several ways.
- When it consulted on the Duty, the FCA wrote that "Firms would not be able to transfer their responsibilities to other firms" (CP21/36, paragraph 3.22).
- Its December 2025 statement on firms working together says responsibilities should reflect each firm's actual role and that "it shouldn't be possible for responsibility to slip between the cracks". It also notes that it doesn't deal with working with unregulated parties, where the regulated firm stays responsible for the FCA requirements.
- The FCA's alert on advisers accepting business from unauthorised introducers and lead generators tells firms to carry out "robust due diligence on the introducers you transact with", have "a robust vetting procedure" to check introductions were sourced legitimately, and keep full ownership of the advice process.
A note on that last one, because it gets misquoted. The alert was first published on 1 August 2016. Its page shows it was last updated on 17 July 2026, but the change note says only "Link changed for Pensions scams". The expectations themselves haven't changed in 2026. They didn't need to: they were already clear.
Many lead suppliers (us included) aren't authorised by the FCA, so the Duty doesn't apply to them directly. An introducer finding clients for an independent adviser can rely on the article 33 exclusion in the Regulated Activities Order and be paid for it (PERG 8.33). That's legal. It also means everything a compliance officer needs to see has to be asked for.
What should an introducer due-diligence checklist cover?
This is the list we'd want in the file before the first appointment, and again at each review. Each line says which rule or FCA concern it answers, so you can show why it's there.
| Check | What good evidence looks like | Why it's there |
|---|---|---|
| Who they are | Company number, directors, registered office, ownership, any links to product providers or other advice firms | FCA introducer alert (introducers benefiting from the investments); independence under COBS 6.2B |
| Sourcing | Channel for every prospect (paid social, search, their own site). No bought lists, co-registration or data "partners" | FCA alert: introductions "sourced legitimately"; ICO consent rules |
| Financial promotions | Copies of adverts and landing pages, the name of the firm that approved them under s21 FSMA, approval dates | FSMA s21; approver permission required since 7 February 2024 |
| No cold calls | Written confirmation that nobody calls consumers about pensions unless they asked to be called | PECR regulation 21B (pension cold-calling ban, January 2019) |
| Qualifier and script | Every question the consumer answers, word for word. No attitude-to-risk questions, no product or transfer steer | FCA alert warning signs: introducers helping with fact-finds or risk questionnaires, or influencing the choice |
| Consent | The consent wording, naming your firm (or telling the consumer your name before contact), plus a timestamped record per prospect | ICO: consent to a third party must name it; UK GDPR Art 7(1) says you must be able to demonstrate consent |
| Exclusivity | A written statement that each prospect goes to one firm and is never resold | Consent is specific to a named recipient; resale is also a quality and complaints risk |
| How they're paid | The fee basis. Does any payment change with product, provider, amount invested or whether the client transfers? | FCA alert (introducer benefiting); FG21/3 on DB transfer introducer payments |
| What the consumer is told | That advice is paid for; that the adviser pays for the introduction; which firm they'll speak to | Consumer understanding outcome; fair, clear and not misleading |
| Data handling | Data-sharing terms, who is controller when, retention, what's sent to ad platforms | UK GDPR; ICO direct marketing guidance |
| Complaints | How a consumer complains about the introducer, and how complaints about advice reach you | Consumer support outcome; DISP for your side |
| Ongoing monitoring | A review date, a sample of adverts rechecked, outcome data (shows, disqualifications, complaints) | FCA alert: "regularly review" your systems and controls; PRIN 2A.9 outcomes monitoring |
Two things are easy to leave out: the actual advert, and the consent record for a specific named prospect. Ask for both, and pick one or two prospects at random to trace from advert to diary.
If you'd like a shorter version for a lead source you're already using, the ten warning signs are in pension lead red flags.
How do you evidence target market for bought-in clients?
Your target market is defined in your own Duty documents: who your service is for, and who it isn't for. The distributor rules in PRIN 2A.3 and the outcomes monitoring in PRIN 2A.9 expect you to check that you're actually serving that group and to act if you're not.
Referral clients have to fit your target market too, but you usually know the referrer and how they describe your service. With bought clients, who arrives is shaped by someone else's advert and qualifier, so you need the link to your criteria in writing. Practically:
- Write your criteria as filters. Minimum assets, age range, the advice areas you cover, meeting types, regions, whether you'll see DB pension holders at all.
- Get the criteria applied before booking. The supplier's qualifier should screen against your filters, so people outside them never reach your diary.
- Keep the answers on file. The prospect's own answers, dated, are your record of why they fitted.
- Record the misses. How many shows turned out to be outside your target market, and what the supplier did about it. That's outcome data, and it's what the FCA's 2023 frameworks review said firms were short of.
- Record who you turned away and where you sent them. A prospect who isn't a fit still deserves a sensible signpost (MoneyHelper, Pension Wise, another firm).
Here's what a single entry might look like. It's an illustrative example, not a template the FCA has endorsed:
| Field | Illustrative entry |
|---|---|
| Source | Paid social advert, version and approval date on the supplier's ad register |
| Consent | Wording agreed, timestamp, firm named before contact |
| Stated criteria | Pot band, age, retirement stage, help wanted, fee acknowledgement |
| Your filters matched | Minimum pot, advice areas, meeting type, DB holders yes/no |
| Meeting outcome | Attended; pot reconfirmed or not; within target market or not; vulnerability noted and how you adapted |
| Result | Became a client, declined, referred elsewhere; any complaint |
| Review | Date the source was last rechecked, by whom |
A self-declared pot band isn't proof of anything, so treat it as a filter, reconfirmed in the meeting. Ours is £250k+ in defined contribution pensions, self-declared, reconfirmed on the call, and credited back if it turns out lower. If you set a higher minimum (£500k or £1m) and the prospect confirms pensions below the band you selected, the show is credited, even if they hold £250k or more. That's a commercial policy as much as a compliance one, but it gives you a clean record either way.
What do vulnerable customers (FCA) mean for a lead source?
FG21/1 defines a vulnerable customer as someone who, because of their personal circumstances, is especially susceptible to harm, particularly when a firm isn't acting with appropriate levels of care. It groups the drivers into four: health, life events, resilience and capability. After its March 2025 review, the FCA said it wouldn't rewrite the guidance or add new rules, but that outcomes for people with characteristics of vulnerability still needed work.
The scale matters for pension work. The FCA's 2024 Financial Lives survey estimated that 49% of UK adults, about 26.4 million people, show at least one characteristic of vulnerability. Retirement is a life event in its own right, and people approaching it are often dealing with bereavement, ill health or caring at the same time. Some share of every appointment stream will include vulnerable people. The question is whether the funnel makes things worse.
What to expect from a lead source, and what to check:
- No pressure mechanics. No countdown timers, "limited places" or "act before the rules change" hooks. Deadlines like the April 2027 inheritance tax change are real, but they shouldn't be used to rush people.
- No health data collected without a reason. Health is special category data under UK GDPR. A booking form doesn't need it; the adviser handles vulnerability in conversation.
- Plain language about cost. The consumer should know advice is paid for before they book, so nobody arrives expecting it free.
- An easy way to cancel or rebook. People's circumstances change between booking and meeting.
- No penalty for doing the right thing. If you find in the meeting that someone can't be advised (a clear lack of capacity, for example), you shouldn't be charged for it. Otherwise the fee itself pushes the wrong way.
Then it's on your side: identifying vulnerability in the first meeting, recording it and adapting. The supplier can't do that for you and shouldn't try.
Which lead fee models are easiest to defend?
We'll be open about our bias here, because we sell one of these models. The FCA doesn't rank fee models, and none of these is compliant or non-compliant on its own. The table is our commercial view of what each one leaves you to test.
| Fee model | What you pay for | Consumer Duty and introducer points | What to test |
|---|---|---|---|
| Per lead (shared) | Contact details, often sent to several firms | Consent may be to "partners" generally; the consumer gets several calls; hard to evidence target market | Consent wording; how many firms contact each person |
| Per lead (exclusive) | One firm's enquiry | Better consent position; you still chase, and pay for people who never answer | Source, consent, contact rate |
| Subscription plus per enquiry | Platform access and enquiries | Usually well-documented platforms; cost per client can swing widely month to month | Cost per client over several months; refund terms |
| Flat fee per attended meeting | A meeting that took place | Same fee whatever the client decides, whichever product, however much invested. Introducer has no stake in the outcome. Cost per client is calculable | The show definition and credit rules; sourcing and consent still apply (our model) |
| Share of initial fee or assets | A client who signs | Introducer is paid more if the client invests more or agrees to more. Worth scrutiny against the FCA's "benefit directly" warning sign | Who talks to the client before you, and what they say |
| Paid only if a DB transfer proceeds | A transfer | The FCA's DB guidance (FG21/3) says advisers can't pay an introducer according to whether advice results in a transfer | Not an option for DB transfer work |
Why do we call a flat per-show fee a Consumer Duty positive? Not because it's cheap or because anybody has blessed it. It removes one specific risk: the introducer's interest in what the client does next. Sourcing, promotions, consent and your own incentives still need checking. The FCA's introducer alert lists, as a warning sign, an introducer who "benefits directly" from the resulting investments. A fee that's identical whether the client consolidates, draws down, buys an annuity or does nothing at all can't create that benefit. And it means your file can say, in one line, what you pay and why it doesn't bias the advice.
Share-of-fee introducer deals aren't banned for most advice work, and they can be run well. They just need more explaining, especially where the introducer has any say in what the client is told.
What questions should you ask any lead supplier?
These are the ones we'd send before a call, so the answers come back in writing.
2. Does anyone on your side phone consumers about pensions who didn't ask for a call?
3. Do you buy, rent or share data with anyone?
4. What does the consumer agree to, word for word, and when are they told my firm's name?
5. Is each prospect sent to one firm only? Is that in your terms?
6. What questions do you ask, and do you ever ask about risk, products or transfers?
7. How are you paid, and does anything change with what the client decides or how much they invest?
8. What's the consumer told about advice fees before booking?
9. What happens to prospects who don't fit, and to their data?
10. How does a consumer complain about you, and how do you tell me?
11. What outcome data will you give me each month?
12. Who can I speak to if something goes wrong?
If a supplier answers the first three vaguely, dig further before you accept an introduction.
How does InvestmentsBooked answer the checklist?
We'd rather show our answers than claim we're the safe choice. You can judge.
- Status. InvestmentsBooked is not authorised by the FCA and does not give financial advice. We sell only to FCA-authorised firms giving independent advice.
- Promotions. Every consumer advert is approved by an FCA-authorised firm under section 21 of FSMA before it runs.
- Calls. We don't make unsolicited pension marketing calls. Reminders are service messages by email or SMS.
- Consent. The prospect asks us to book them with one FCA-authorised independent firm. We share their answers with that one firm only, and we tell them the firm's name and FRN as soon as it claims the booking, before the call. One appointment goes to one firm and is never resold.
- Transparency. Consumers are told before booking that advice is paid for and that the adviser's firm pays us for the introduction.
- No advice. We don't fact-find, ask about attitude to risk or suggest products. We record facts and intent; the advice process is yours.
- Fee. £500 per qualified show (no VAT added), the same whatever the outcome. Minimum purchase of 10 appointments (£5,000); credits valid for 6 months. No-shows and disqualified meetings are credited back to your balance. Credits that come back to your balance (a no-show, a cancellation that isn't rebooked, a disqualification or any other credit) come back with a fresh 6-month expiry. We supply appointments that match your filters well within the 6 months. If we ever can't before your credits expire, we refund the unused credits.
- DB transfers. People looking to transfer out of a final salary scheme are excluded by default. The reasons are in why we exclude DB transfers.
During onboarding you get our introducer due-diligence pack: sources, example approved adverts, the qualifier script, consent wording, data-sharing terms and our complaints process. We don't make outcome claims we can't evidence. The details sit on our lead quality page, with pricing on pricing and the process on how it works. If you're comparing suppliers generally, the honest buyer's guide is at buy IFA leads.
Sources and checks. FCA Handbook: PRIN 2A.4 (price and value), PRIN 2A.3, PRIN 2A.9, PERG 8.33, COBS 6.1A and 6.2B. FCA: introducer and lead generator alert (1 August 2016, last updated 17 July 2026); fair value frameworks review (May 2023); Consumer Duty good practice (February 2024); ongoing advice review (2025); CP21/36; statement on firms working together (December 2025); FG21/1; vulnerability review (March 2025); Financial Lives 2024; FG21/3. ICO: using marketing lists. Proposed changes to the Duty's scope (CP26/23) were still proposals on the check date. Conversion rates in the formula are illustrative. Figures checked 27 September 2026. This isn't legal advice. InvestmentsBooked is not authorised by the FCA and does not give financial advice.