The good news is all the 24 firms in the desk review had a vulnerable customer policy.

But the bad news was not all were actively collecting the data, monitoring the outcomes, and reviewing the policy.

This is a case where too many had adopted the approach of ‘set and forget’. 

What’s next? 

The FCA’s thematic review covers a lot of ground in good detail. 

The FCA is not being vague; together with its 'Dear CEO' letter it is easy to see what areas it wants firms to review. 

It is worth adviser firms reading the report and taking the opportunity to review.

There may be changes or improvements that can be made, and the examples in the report of good practice could help with setting any new direction. 

Any work firms carry out should be set in the context of the consumer duty and the FCA’s expectations and requirements in this area. 

Finally, this is not the last we will hear about retirement income advice.

The FCA makes it clear that this will be a continuing area of focus and further work. 

Rachel Vahey is head of public policy at AJ Bell