THE DEEP DIVE

Big news! The Consumer Composite Investments (CCI) regime is here.

The FCA has released PS25/20, the final rules for CCIs, and the industry is reacting like someone who can’t tell whether the deodorant they got for Christmas is a nice gesture or a subtle message.

It’s bigger than PRIIPs, broader than UCITS KIIDs, and more operationally invasive than a colonic.

It’s 139 pages. We read it, so you don’t have to.

Let’s crack it open.

BACKGROUND

🌽1. What Even Is a CCI?

CCIs are the UK’s new overarching category for retail investment products, with the aim of creating a single, comparable information regime across products.

The regime is the UK’s attempt to finally give retail investors disclosures that are:

  • readable

  • comparable

  • not written like a riddle in a Victorian inheritance dispute

The FCA frames this regime as part of a broader move to “support a thriving retail investment culture,” which is very sweet, very optimistic, and slightly reminiscent of a Pixar protagonist before the plot turns.

But make no mistake, this is the UK’s clean break from the tortured marriage of UCITS KIIDs, PRIIPs KIDs, Consumer Duty guidance sheets, and whatever your firm has been duct-taping together for the last 18 months.

And it’s not optional.

If you manufacture or distribute retail investment products in the UK, CCIs are now your life.

WHAT’S THE BIG DEAL?

🌽2. The Product Summary, AKA: “No, Seriously, Make It Clear This Time.”

The crown jewel of the regime is the new Product Summary, a short, standalone disclosure document required for every CCI.

The rules say it must:

  • be “short and concise”

  • be understandable without cross-referencing other documents

  • equip retail investors to make effective, timely and properly informed decisions

But it should also be digitally native. With buttons to click and layers of information presented in interesting ways.

So, yes, the FCA wants you to write something simple.

And no, you may not hide the real explanations in footnotes.

Think of the Product Summary as the PRIIPs KID after rehab, only without the inevitable relapse.

THE NUMBERS

🌽3. Costs & Charges: The FCA Reopens a Long-Term Beef

If you were hoping the CCI regime might take a relaxed approach to costs and charges…

the FCA would like to gently remind you that this is the hill they will die on.

Here’s what’s actually changing in human language:

1. CEIFs (investment trusts) are getting special attention.

The FCA explicitly calls out years of confusion around:

  • how gearing affects ongoing costs

  • how real-asset maintenance costs distort comparability

  • how fee restructurings magically appear whenever scrutiny increases

So under CCIs, CEIFs must provide cost information that is clean, consistent, and not designed by someone hiding a dark secret.

2. The OCF is being purified.

Two major distortions are removed:

  • Gearing costs → out

  • Real-asset maintenance costs → out

These adjustments aren’t vibes.

They’re about making OCFs comparable across products the way calories are comparable across food labels, even when the recipe is messy.

3. Presentation matters and innovation is explicitly encouraged.

The FCA goes beyond “Tell the truth” and straight into

“Tell the truth in a way normal humans understand.”

The policy statement gives examples:

  • adding Assessment of Value comparisons to contextualise performance vs cost

  • showing maximum drawdown charts so risk feels real, not theoretical

  • comparing your fund versus cash so consumers can see what they’re giving up

This is extremely on-brand with Consumer Duty’s behavioural expectations.

The big picture?

The FCA is saying: ‘we don’t just want the right numbers. We want the numbers presented in a way the average investor can understand without a finance degree or emotional support animal.’

Costs aren’t just disclosures under CCIs.

They’re communication tools, and firms that present them lazily are going to learn the hard way that “non-comparable” is now a regulatory issue, not a formatting preference.

THE DATA PLAY

🌽4. Machine-Readable Files. Hello, Data Standardisation, My Old Friend

Manufacturers must provide machine-readable data for:

  • risk

  • return

  • past performance

Why?

Because distributors keep telling the FCA that ingesting inconsistent PDFs is like trying to do data science on a medieval tapestry.

The FCA agrees. And from now on, if your product summary isn’t machine-readable, it might as well be handwritten in crayon.

The FundFlow Take - Or, How to Survive the CCI Era Without Losing Your Mind

Here’s the truth hiding under the formality:

  • The UK has decided PRIIPs and KIIDs are dead.

  • CCIs are the new baseline for retail disclosure.

  • The Product Summary will become the most litigated document in your firm.

  • Data standardisation is no longer optional.

  • Distribution chains must evidence correct delivery and comprehension.

  • Enforcement powers are now aligned with FSMA’s strongest tools.

  • Consumer Duty is no longer a vibe — it’s in the rulebook’s bloodstream.

“The CCI regime is what PRIIPs wanted to be when it grew up.”

Except this time, the FCA has both the narrative and the enforcement architecture to make it stick.

Until next week!

NEIL PIC OF THE WEEK

Copyright: APEX

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