Bulk migration — moving an entire book of business at once — is increasingly the preferred approach for platform replatforming. The efficiency case is strong: one consent event, one cutover date, and a clean break from the legacy system. But the fiduciary dimension is where many migration programmes underestimate the complexity.
In this article, Dave Howard examines the fiduciary realities that govern how bulk migrations must be structured to meet both FCA Consumer Duty requirements and the adviser's duty of care to clients. The argument is clear: speed, while commercially attractive, cannot be the primary driver when clients' financial futures are in the balance.
The regulatory context
Consumer Duty demands that firms demonstrate positive outcomes for all client cohorts — not just the majority. In a bulk migration, that means every edge case, every unusual holding, and every specialist product must be assessed before consent is sought. Rushing this process creates the exact client harm that FCA is primed to investigate.
Where rigour pays off
Firms that invest in a disciplined pre-migration data audit — mapping every holding, reconciling valuations to the penny, and resolving data quality issues before cutover — consistently achieve better outcomes: lower attrition, fewer post-migration complaints, and cleaner FCA audit trails.
The firms that rush are the ones who end up in remediation. Read the full article on LinkedIn for Dave's complete framework.
