Consumer Duty and Cash: How advisers can turn obligation into opportunity
Consumer Duty reinforces the need for advisers to deliver positive outcomes. With clients holding record cash balances, this often overlooked asset gives an opportunity to strengthen relationships by delivering lasting value.
This article is not advice. It is provided for information purposes and should not be treated as a recommendation. Advisers remain responsible for the advice they provide to their clients.

Should financial advisers be talking to clients about managing cash? Many wealth planners see savings as something clients deal with on their own. Advising on cash is also perceived as time-consuming and extra admin for little reward.
However, discussing cash management opens an opportunity for advisers to deliver on Consumer Duty expectations.
Consumer Duty and better client outcomes
Consumer Duty has set standards with three rules designed to deliver good client outcomes. Advisers are expected to:
- Act in good faith
- Avoid foreseeable harm
- Help clients reach their financial goals.
But to do that properly requires an understanding of all aspects of your client’s wealth. That includes the cash sitting outside of their investment portfolios.
And those cash sums are far from small.
Big savings, small returns
According to the Bank of England, UK households and businesses now hold a record £1.9 trillion in savings. That’s almost double what they held a decade ago. Yet an estimated £1.3 trillion of that is earning less than 2% interest. In April 2024, nearly £275 billion sat in instant-access accounts earning no interest at all.
At a time when interest rates are still far higher than 10 years ago, it’s a sizeable gap. With inflation at 3.8% (as of September 2025), in real terms, clients with these low-interest accounts are actually losing money. It’s also a prime example of avoidable harm.
Getting savings moving
Traditionally, advisers have focused on how much cash clients should hold. Not where it’s held, how it’s managed or what it earns. It’s a misconception that clients will shop around for the best interest rate, or move money when needed. In practice, they often don’t.
The FCA discovered only one in ten adults with a savings account or Cash ISA switched providers in the last three years. For one in five, it felt like too much trouble. Others said loyalty or familiarity with their bank were reasons to stay put.
Generally, that loyalty isn’t returned or rewarded. And that inertia has a cost. Given the statistics, there’s a good chance your clients are earning less than they could. Or exceeding FSCS protection limits without realising.
Talking about how cash is managed can benefit everyone.
For clients, it highlights the potential problems of doing nothing, while helping to protect and grow their savings. For advisers, it demonstrates a clear commitment to the principles of Consumer Duty, adds measurable value, and builds trust in their guidance.
How cash management platforms support Consumer Duty
There are two clear risks when it comes to cash: poor returns and inadequate protection.
The stakes are even higher for clients in or approaching retirement. Many hold large cash buffers for drawdown or near-term spending. Making sure this money is earning a fair rate and fully protected is crucial to support their goals.
A cash management platform like Flagstone can help advisers tackle both, delivering the good client outcomes expected by the FCA.
Flagstone provides access to 200+ savings accounts from over 65 banks – including competitive and exclusive rates. Your clients can spread their cash across multiple banks – maximising FSCS protection for each eligible account. And because they’re all available through one platform, it takes just one sign-up.
More value, minimal admin
For some of our advisers, the sticking point is the belief cash advice adds complexity and paperwork – especially around compliance. In reality, it can slip naturally into the processes you already use for other investments, like suitability reports.
Currently, most advisers record only how much cash their clients should hold, and not where they recommend it should be placed. When reviewing a client’s portfolio, it’s important to discuss and document six crucial points:
- How much cash do they hold?
- How does it compare to the recommended amount?
- What’s it for?
- Where is it deposited?
- Is it fully protected?
- Is it working hard enough?
Detailing the rationale shows the same due diligence for cash as with other asset classes. It also supports compliance with COBS 9 and Consumer Duty requirements, without needing a new, separate procedure.
There are other simple and impactful wins, too. Cash held in SIPPs or stocks & shares ISAs can build up unnoticed. They can also earn a lot less interest than a cash management platform typically offers. A quick review can result in better returns and show clients you have their best interests at heart.
Time-saving technology
Platforms like Flagstone let your clients build a cash portfolio in one place – and ensure they’re earning the interest they deserve. And they let you maintain total visibility of your clients’ balances, their performance, and FSCS coverage. All at a glance.
But these benefits needn’t cost you time. Your clients remain in complete control of their cash – so you won’t need to add it to your to-do list. It’s a convenient way to keep track of their money and identify opportunities without taking complete responsibility for it.
There’s an obvious, but often overlooked connection between cash, compliance and Consumer Duty. Acting in good faith and avoiding foreseeable harm means knowing where cash sits, how it’s protected, and what it’s earning.
It’s also good for business. Cash conversations can add trust and loyalty, and open doors to new referrals. And turning cash into a strong part of any investment portfolio is easier than you might expect.
To learn more about cash compliance, understand client attitudes, and build a stronger cash strategy, read our Cash Strategy Guidelines.


