Partner Michelle Quinn has provided comment in Law360 on the potential impact that the FCA’s public identification of The Claims Protection Agency and its increasing willingness to use its power to protect consumers, might have on targeted support.

Commenting on the likelihood of companies offering targeted support being named in subsequent enforcement investigations where the support is promoted through a misleading consumer marketing campaign, Michelle said: “Absolutely. The FCA has been increasingly focused on the way financial services firms communicate with consumers, and this includes the marketing of any form of targeted support. Recent enforcement activity shows a clear trend: the FCA is more willing than ever to intervene, publicly name, and act where promotions are misleading, unclear, or not properly understood by the intended audience.

“Against this backdrop, advisers, investment firms, banks, and insurers face a genuine risk of being drawn into enforcement investigations if their targeted‑support promotions fall short of regulatory standards. Wide‑reaching campaigns can amplify misunderstandings and expose firms to allegations of systemic failings, especially under the Consumer Duty, which requires firms to ensure communications are comprehensible and do not cause foreseeable harm. In short, firms offering targeted support must treat their marketing with the same rigour as any other financial promotion, recognising that regulators are prepared to act – and to name firms – where consumer understanding and protection are compromised.”

Discussing the damaging impacts of an FCA investigation, Michelle commented: “When the FCA publicly names a firm in connection with an investigation, the impact rarely stays neatly contained within the specific business area under scrutiny. Even if the investigation relates solely to targeted‑support activities, the act of naming the firm can create a much broader perception problem. Customers, counterparties, and the market generally do not distinguish between different business lines when assessing trust and credibility. A public investigation can therefore cast doubt over the firm’s overall governance, culture, and controls, causing detriment to the whole business.

“In short, once a firm is publicly associated with misleading communications or consumer harm, the narrative may well take on a life of its own, regardless of how narrow the scope of the underlying issue and any eventual determination by the FCA. Unfortunately, in terms of public perception, there will inevitably be an element of “there is no smoke without fire” regardless of the investigation’s outcome.”

Michelle’s comments were published in Law360, 13 January 2026.