Section 165 requests are one step from enforcement—wealth management, private banking and stockbroking boards should act before an information request becomes an investigation.

The Financial Conduct Authority’s (FCA) expanded use of Section 165 (s165) powers in 2024–2025 highlights why Boards should urgently add s165 readiness to their agenda—especially with the next regulatory episode on the horizon. 

Section 165 allows the Financial Conduct Authority to request information and documents from firms to support its supervisory and enforcement functions. The FCA has increasingly utilized this power across various sectors to obtain information not captured through regular regulatory reporting.

Recently, the FCA issued new s165 information requests, signaling a strategic shift towards a more data-driven supervisory approach that prioritizes client outcomes. This section is part of the FCA's broader enforcement powers under the Financial Services and Markets Act 2000, which enables them to gather information and appoint investigators as needed.

Many firms remain exposed by questionable or unreconciled data in key trading, risk, accounting, and reporting systems. This is despite “no material issues” found within both internal and external audit, risk, and compliance reports which have been duly signed off by Boards.

With FCA requests intensifying and deadlines shortening, the stakes are higher for delivering complete, accurate, and defensible submissions. This is precisely where Fractyl Consulting’s risk, compliance, operations, and project management expertise delivers value.

Our team helps Boards and their Senior Management Function (SMF) holders produce robust returns, run deep data validation, and address weaknesses in current data architecture or system interoperability.

For boards seeking assurance and resilience in upcoming regulatory cycles, engage Fractyl Consulting to future-proof governance and operational controls—before the next request arrives.