Pre-engagement, in-flight and post-engagement support.

For firms responding to FCA, PRA, or TPR enquiries — methodology defence, response drafting, sample reproducibility exercises, and engagement with the regulator's technical team. The firm's authorisations and CMC™ convention support credible engagement on substantive technical matters.

The regulators

Financial Conduct Authority

Conduct, retail-product, redress methodology, claims-management regulation, Consumer Duty, advice-quality matters. The firm engages with the FCA across DISP App 4 redress engagements, DB transfer methodology challenges, claims-management firm enquiries, and forthcoming Value for Money regime engagement (CP26/1).

Prudential Regulation Authority

Capital adequacy, reserving methodology, technical-provisions challenges in insurance and reinsurance contexts. The firm engages with the PRA where actuarial methodology is the substantive question — in matters involving sponsor-covenant assessment, scheme-funding under the Pensions Act 2004, and insurance-company solvency matters where pension liabilities feature.

The Pensions Regulator

Scheme funding (Funding Code, fast-track / bespoke), trustee governance, sponsor covenant, transfer-value programmes, master-trust authorisation, forthcoming VFM regime engagement. The firm's pension-valuations practice and the platform's calculation control IDs supply substantive material for TPR engagement.

Three phases of engagement

Pre-engagement

Where the firm has identified a possible regulatory enquiry on the horizon — a methodology that may be challenged, a redress book that may attract attention, a technical area where the regulator is signalling concern — pre-engagement support sets up the firm's position before the enquiry arrives. Methodology articulation, sample reproducibility ahead of skilled-person review, and engagement-protocol drafting are the typical work-streams.

In-flight

During an active regulatory enquiry — methodology defence, response drafting to specific information requests, sample reproducibility under skilled-person review, technical engagement with the regulator's specialist team. The firm operates as a substantive technical adviser, not as a regulatory-strategy consultant; the work is methodology-grade rather than relationship-grade.

Post-engagement

Where a regulatory enquiry has reached findings — remediation programme design, methodology-update implementation, regulator-required scheme-funding adjustment, redress-programme execution. The firm's productised Solutions (particularly Redress & remediation, and BPA Fair-Value Pricing) often supply the operational delivery of post-enquiry remediation under separate engagement.

Where the firm fits

Regulatory engagement work splits broadly into two complementary roles: technical (the methodology, the sample, the calculation, the apparatus) and strategic (the relationship, the negotiation, the political dynamics, the timing). The firm operates in the technical role. Where strategic regulatory advice is required — relationship management with the regulator's senior team, cross-sector positioning, escalation-routing — that work sits with regulatory law firms and dedicated regulatory-strategy consultancies. The firm's role is to make sure the technical apparatus underpinning the engagement is defensible.

This division matches the regulator's own organisational structure: technical specialists on the one side, supervision-relationship managers on the other. Substantive technical engagement with the technical specialists is what the firm contributes; the supervision relationship belongs to the firm's regulatory legal advisers and senior management.

The CMC™ convention as engagement material

The firm's Check My Calculation™ artefacts — produced for every productised engagement and for many advisory engagements — are engagement-grade material for regulatory dialogue. A CMC™ ties an output figure to a calculation control ID, the configuration in use, the data schema applied, and the audit log of every calculation step. Where a regulator asks the question "show us how you got from inputs to outputs", the CMC™ is the answer.

For firms preparing for FCA enquiry, PRA examination, or TPR scheme-funding review, the firm can supply CMC™-grade documentation of methodology in advance — the apparatus the regulator's technical team will engage with when the enquiry arrives.

Cross-reference

For specialist actuarial support within s166 engagements — instructed by the firm in scope or by the appointed skilled person — see S166 engagement support. For expert-witness work where regulatory matters become litigated, see Expert witness.

Engagement and pricing

Scoped through a first conversation with the firm.

Fixed-fee engagement

For well-defined regulatory submissions: technical responses to specific FCA or TPR queries, position papers on methodological matters, or reviews of disclosed methodology. Fee agreed at scoping.

Time-and-materials

For matters where the regulator's position is still developing or the firm's role evolves: ongoing supervisory engagement, multi-phase technical work, or thematic-review involvement. Rate agreed at scoping; senior-led throughout.

Statement of Work — how the fee is fixed

Engagements are scoped through a first conversation and then fixed in writing before any work begins. The firm’s Invitation Letter contains a Statement of Work fixing: the scope of the engagement, the timetable for delivery (key milestones and final-deliverable date), the price (with any stage payments scheduled against milestones), and the named individuals on both sides.

The scope-to-price conversion is based on the firm’s published charge-out rate: £350 per hour for engagements led by a Director or Senior Actuary (the only grades that lead engagements at Congruent). The Statement of Work converts scoped hours into a fixed fee — the buyer’s commercial commitment is to the fee in the Statement of Work, not to an open-ended hourly meter.

The firm tends to come in competitively on the fixed quote. Because Directors lead engagements directly — without the layered team structure typical of larger firms — scoped hours convert into a fixed fee that compares favourably against equivalent senior-led work elsewhere in the market.

Rate as at 1 January 2026, reviewed annually.

The methodological position behind the engagement.

Cross-references

For specific s166 instructions, see S166 engagement support. For methodology challenges reaching tribunal or court, see Expert witness.

Regulatory engagement

If the regulator has signalled a substantive technical concern, the first conversation is technical.

Pre-engagement support is most valuable; in-flight engagement is most common; post-engagement remediation is what the firm's productised Solutions deliver. The firm responds within one working day with whether it can engage and what conflicts (if any) apply.

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