Compliance software or a compliance consultant? What a firm actually gets for the money

At some point every regulated firm asks the same question. A consultant on retainer costs £400 to £1,500 a month. Compliance software costs a flat monthly fee. Both promise that the FCA will be satisfied. Which one should the money go on?

The honest answer is that they are different purchases, and the firms that get value from either are the ones that understand what each actually delivers. This article is a fair account of both: what a retainer buys, what a platform does and does not do, when you need both, and how to decide. It is written by a firm that sells software, so read it with that in mind, and note that a good number of our own customers are consultants running their clients on it.

What a retainer buys

A consultant’s hours are expensive for a reason. What you are paying for is judgement, and judgement is the part of compliance no register can hold.

• Interpretation. A new rule arrives, a Dear CEO letter lands, a policy statement changes a definition. Someone has to say what it means for your permissions, your products and your customers. That is a judgement about your business, and it is what a good consultant is for.
• A person to call. A complaint escalates, a senior manager resigns, a customer turns out to be a politically exposed person. The value of a retainer on that day is a phone number and an answer from someone who has seen it before.
• Bespoke documents. A compliance manual, a Consumer Duty assessment, a financial crime risk assessment written for your business model rather than adapted from a template.
• Representation. When the FCA writes, visits or commissions a skilled person review, a consultant who knows your file can sit alongside you.
• Periodic review. A quarterly or annual visit that looks at files, tests controls and tells you where you fall short.
• Training. Conduct rules, financial crime, the Consumer Duty, delivered to your people by someone who can take questions.

Notice what is not on the list. Keeping the registers up to date every week. Chasing the deadlines. Holding the evidence in one place so it can be produced on demand. Building the board report from what actually happened. A retainer can include some of that, but it is billed at the same hourly rate as the judgement, and it is the part of a consultant’s month that a firm most resents paying for.

What a platform does

Compliance software does the structural work. At a flat monthly price, a platform like Fenchurch One gives a firm:

• Registers, ready made for the records the FCA expects a firm to hold: complaints, conflicts of interest, breaches, gifts and entertainment, financial promotions, fraud and more, every entry dated, owned and evidenced.
• Attestations that turn each ongoing obligation into a tracked record mapped to the Handbook, so “we comply with SYSC 6” becomes a dated statement with the evidence behind it.
• A Control Centre with every due-dated task across the firm on one view and a weekly email digest, so a return, a renewal or a review is chased before it is overdue.
• A dashboard that shows, from the firm’s own records, what is on track, what needs attention and what is overdue.
• People records for every director, employee, contractor and outsourced provider, with fit and proper assessments, Statements of Responsibilities and due diligence held on the person, and no limit on how many people you record.
• A proof pack. One click builds a branded, dated evidence bundle of the firm’s position, its open items and the records behind them, for an auditor, the directors or the regulator.
• A Live Link. A read-only view of the evidence, with an optional passcode, an expiry and a view log, that can be revoked at any time. For the day someone says “show me”.
• Reports drafted from the records the firm has actually kept, from a one-page executive summary to a full compliance report for the directors, with the gaps stated as gaps.

What a platform does not do

It does not make judgement calls. It will tell you a fit and proper assessment is overdue; it will not tell you whether the answers on it are acceptable. It will hold your Consumer Duty attestation; it will not decide whether your fair value assessment stands up. It will not interpret a new rule for your business model, answer the FCA’s letter, or take responsibility for what it holds.

That is not a limitation to apologise for. A platform is where the work is recorded and evidenced. The thinking stays with the firm, or with the people the firm chooses to advise it.

Where the money actually goes

Put the two side by side and the shape of the decision becomes clear.

A retainer at the lower end, £400 a month, usually buys a few hours: a call, a review of something, a quarterly check. At the upper end, £1,500 a month, it buys a day or two, and the consultant will often spend part of that on production work: formatting a board report, updating a register from your emails, assembling evidence for a visit.

A platform at a flat monthly price does the production work every day, for everyone in the firm who needs to use it, and produces the evidence on demand. It does not buy a single hour of advice.

So the question is not which is cheaper. It is what your firm needs bought.

When you need both

Some situations call for a consultant whatever software you run.

• Authorisation and variations of permission. Applications are judgement-heavy, and a consultant who has taken firms through the gateway earns the fee.
• An FCA contact. A visit, an information request, a section 166 review. You want someone beside you who has done it before.
• A complex or unusual business model. Client money, MiFID investment business, funeral plans, anything where interpretation is most of the work.
• A change you have not made before. Appointing a first appointed representative, launching a product to a new market, moving into a new sector.

In each of these the platform makes the consultant cheaper to use. They arrive at a firm whose registers are current, whose evidence is dated and in one place, and whose position can be shared through a Live Link before the first meeting. The hours go on judgement, not on reconstruction.

When a platform on its own is enough

An established firm with a clear permission set, a settled product range and someone competent in charge of compliance mostly needs the structure done properly and the evidence kept. That firm does not need a retainer to hold its complaints register or to remind it that a return is due. It needs a platform that does those things every day and a consultant it can call when something genuinely new happens.

That is also the model many consultants prefer. Their clients run the platform; the consultant reviews the position through it, advises on what it shows, and stops being paid to chase spreadsheets.

A short decision test

Answer these honestly.

1. In the last 12 months, what did your consultant’s hours actually go on: advice, or keeping records straight?
2. If the FCA asked for your complaints register, your conflicts register and your last board report tomorrow, could you produce all three, dated, by lunchtime?
3. Does anyone in the firm know today what is overdue?
4. When a rule changed this year, who worked out what it meant for you?

If the answers to 2 and 3 are no, the gap is structural, and a platform closes it. If the answer to 4 is “nobody”, the gap is judgement, and a platform will not close it. Many firms find the answers point both ways, which is why the two purchases sit together rather than against each other.

What Fenchurch One includes at a flat monthly price

Starter, Growth and Pro are flat monthly plans, month to month, with no setup fee and no minimum term. Every plan includes the core registers and attestations, the Control Centre, the dashboard, unlimited people records, the executive summary report and a form builder for any register of your own. The full library of 29 registers and 13 attestations, the 41 policy templates and the full compliance report come in from Growth; the FCA dry run, the 74-chapter compliance monitoring plan, the FCA Returns tracker and the Due Diligence module on Pro. For comparison, platforms doing similar work start at more than £1,000 a month, and an off-the-shelf compliance manual costs £765 to £975 one-off and holds no records at all.

There is a 14-day free trial. Your card is taken at checkout and nothing is charged until day 14, so you can put your own registers on a board and decide with the evidence in front of you.