The FCA failed to take swift and effective action at all stages of the BSPS case. It first became aware of the risks of unsuitable transfer advice in 2015 after the introduction of the Pensions Schemes Act but failed to take sufficient action to prevent consumers from being harmed. At the time, it did not have adequate insights into the behaviour of smaller advice firms and its work was limited to high-level market wide research to identify high- risk firms, rather than specific, targeted interventions.18 This lack of proactive intervention highlights clear limitations with the FCA’s supervisory approach, and the impacts of the BSPS case demonstrate its failure to prevent harm before it has fully manifested itself in the market.19 The FCA recognised that there were significant issues in its supervision of small advice firms, which did not deliver the necessary oversight, and told us that this was a key contributing factor to the financial harm experienced by members.20