Insolvency Practitioners (IPs) and Wealth Managers are under increasing scrutiny from the Financial Conduct Authority (FCA). Among the many compliance requirements, one that’s easy to overlook is the obligation to maintain accurate and up-to-date client contact details.

This isn’t just good housekeeping. Out-of-date data can trigger delays, create regulatory breaches, and leave firms exposed to enforcement or reputational damage. The FCA expects firms to keep records current, and to be able to demonstrate that they can reach clients when needed.

That’s where Vilcol comes in: offering large-scale, cost-effective people tracing from as little as £10 per client record, with premium in-depth options available for complex cases.

The Risks of Out-of-Date Client Records

• Missed regulatory notices or statutory communications
• Breaches of Consumer Duty or insolvency obligations
• Complaints, reputational damage, and consumer harm
• Inefficient processes and costly last-minute tracing exercises
• Potential fines or penalties if found non-compliant in an FCA review or audit

One wealth management firm recently faced FCA intervention after failing to keep client details current. A clear reminder that this is more than just admin.

The FCA’s Expectations

For Insolvency Practitioners:

The FCA’s Guidance for Insolvency Practitioners (FG25/2, published April 2025) makes clear that IPs appointed over regulated firms must ensure client communications are maintained and records are accurate. Failure to do so risks breaching regulatory duties and delaying key insolvency processes.

For Wealth Managers:

The FCA’s Consumer Duty (in force since 2023) requires firms to deliver “good outcomes” for clients. That includes ensuring customers receive important communications - which can’t happen if contact details are outdated. The FCA has also written directly to wealth and stockbroking firms, warning that poor record-keeping and inadequate oversight are under review.

For All Firms:

FCA rules on systems and controls (SYSC 9) require firms to keep orderly, accurate records that allow the regulator to monitor compliance. Data protection laws (GDPR and the Data Protection Act) add another layer of legal duty to maintain accuracy. Put simply: the FCA expects firms to verify and update client records at least annually and be able to prove it.

How Vilcol Helps

Vilcol specialises in large-scale tracing projects, helping firms verify thousands of client records efficiently. Recent assignments have involved verifying 2,500 to 10,500 client accounts for regulated firms under FCA pressure.

• Affordable: Traces from as little as £10 per client record
• Scalable: Capacity to handle thousands of cases in bulk
• Premium Support: In-depth tracing available for complex or higher-risk accounts (from £85 per trace)
• Compliance-Focused: Delivering the verified, up-to-date contact details firms need to demonstrate compliance with FCA requirements

By outsourcing tracing, firms free up internal teams, avoid bottlenecks, and reduce the stress of regulatory deadlines.

Case Example

Vilcol recently assisted an Insolvency Practitioner tasked with tracing thousands of client accounts. With regulatory obligations looming, the IP needed reliable contact details fast. By verifying each record, Vilcol ensured the firm could demonstrate compliance, avoid delays, and satisfy the FCA’s requirements. All without overwhelming their internal resources.

Best Practice Tips

• Review and update client records every 12 months
• Prioritise high-risk or high-value accounts for deeper checks
• Document all tracing and verification steps for audit purposes
• Build tracing into compliance planning rather than leaving it until urgent situations arise

For Insolvency Practitioners and Wealth Managers alike, maintaining accurate client records is more than a regulatory box-tick. It’s a safeguard against fines, delays, and reputational damage.

Vilcol offers the scale, accuracy, and cost-effectiveness firms need to stay ahead of FCA expectations. With tracing from £10 per record and premium options available, we make compliance simple, efficient, and stress-free.

Don’t get caught off guard. Contact Vilcol today to keep your client data fresh and compliant.