PIMFA response to Consultation Paper 25/9 – Further proposals on product information for Consumer Composite Investments

In April 2025, the FCA issued a follow up consultation to CP24/30, CP25/9 – further proposals on product information for Consumer Composite Investments. PIMFA shares the FCA’s aim of delivering better consumer outcomes and increasing transparency. However, we retain the view expressed in our response to the previous consultation that as currently conceived, the CCI proposals will not result in the simplicity and clarity the industry had hoped for. As it continues to refine the final regime, the FCA needs to ensure that its expression of what the regime represents and the practical implications which fall on industry to deliver it are aligned. This means prioritising the disclosure of information which is accurate, understandable and comparable across the full spectrum of client facing disclosures. We remain concerned that this disconnect between the two has not been sufficiently addressed and as a result, we run the risk of creating more confusion for industry and consumers, not less.