For many years, the client relationship in financial markets was relatively easy to identify. A client banked with a bank, invested through an adviser, traded through a broker, or bought a product from an asset manager or insurer. The same institution often controlled the brand, the product, the advice or execution channel, the servicing relationship and the complaint process. This did not make the traditional model perfect, but it did make the question of responsibility easier to locate.
That model is changing. In modern financial markets, the client journey is increasingly fragmented across multiple parties. The product provider may still hold the licence, but it may no longer control the full client relationship.
The unbundling of the client journey
The modern financial value chain has become increasingly unbundled. Product manufacturing, distribution, marketing, data analytics, execution, custody, payments and client servicing may all sit with different entities. In financial services, this matters because client decisions can directly affect savings, investments, leverage, liquidity and financial resilience.
The question is no longer simply: who provides the product? The more important question is: who shapes the client’s expectations, behaviour and decision-making before the product is used? This is where the accountability question begins.
This creates a gap between where legal responsibility sits and where client influence may actually occur.
Distribution is becoming a source of market power
In financial markets, distribution has always mattered. What has changed is the scale, speed and opacity of digital distribution. The “owner” of the relationship may increasingly be the party that controls attention, not merely the party that controls the product.
This is particularly relevant in an environment where platforms, affiliates, comparison websites, influencers and embedded finance channels can shape client behaviour before the regulated provider has any direct contact with the client. The industry has seen the growing role of online channels, finfluencers and digital engagement practices in shaping retail investor behaviour, including potential risks around misinformation, excessive risk-taking and online imitative trading (Gerritsen & De Regt, 2025).
This creates a subtle conduct challenge. A regulated provider may have compliant documentation, appropriate disclosures and formal onboarding controls, while the client’s expectations have already been shaped by a third-party channel. The provider may therefore inherit conduct risk it did not fully create (Roy, 2022).
Data is becoming part of the relationship
Client ownership is no longer only about brand loyalty or contractual contact. It is increasingly about data. The party that understands client behaviour may have more practical influence than the party that issues the product.
The Bank for International Settlements (BIS) has described the data-network-activity feedback loop in big tech financial services, where data and large user networks can reinforce market position, while also raising questions around competition, data use, operational dependence and financial stability (Doerr et al., 2023; Boissay et al., 2021).
Data can improve personalization, reduce friction and support more relevant financial services. But it can also create conflicts where client insight is used primarily to increase conversion, cross-sell products or deepen dependency on a platform ecosystem.
The rise of embedded finance
Embedded finance adds another layer of complexity. Financial products are increasingly offered within non-financial environments such as payment wallets, e-commerce platforms, payroll systems and digital marketplaces. The client may not actively seek out a financial institution; the financial service appears at the point of need, inside another customer journey.
In this environment, the brand the client trusts may not be the regulated entity. The licensed provider may carry the formal obligation, while the platform carries the client’s trust.
Accountability gaps in a fragmented ecosystem
The central issue is accountability. If a client experiences a poor outcome, who should be held responsible? The product provider? The platform? The affiliate? The influencer? The technology provider that designed the journey?
The answer cannot be that every participant is equally responsible for every outcome. That would be impractical and would risk over-regulating ordinary commercial activity. But it is equally unsatisfactory to locate accountability only in the final contractual relationship if meaningful influence occurred earlier in the journey.
The UK Financial Conduct Authority’s Consumer Duty provides a useful parallel. It places emphasis on customer outcomes across the distribution chain, including how firms oversee third-party relationships where different parties influence the customer journey. The regulatory direction is clear: accountability increasingly needs to follow the wider ecosystem of influence, not only the final regulated transaction (FCA, 2024).
The South African relevance
For South Africa, the FSCA’s Treating Customers Fairly framework provides a useful local reference point. TCF is an outcomes-based regulatory and supervisory approach requiring regulated financial institutions to deliver fairness outcomes across the product life cycle, from product design and promotion through advice, servicing, complaints and claims handling (FSCA, n.d.). This life-cycle approach is especially important where the client journey is split across multiple parties.
In practical terms, South African financial institutions should not only ask whether the regulated transaction is compliant. They should also ask how the client was acquired, what expectations were created, how third-party distribution is governed, how data is used, and whether the client understands who is responsible at each stage of the journey.
Why ownership should follow influence
The modern client relationship should therefore be understood not only through legal form, but through influence.
Regulated institutions remain central to market integrity and client protection, but they may need to manage a wider set of risks than before. Third-party distribution, affiliate arrangements, embedded channels, data-sharing partnerships and platform dependencies should be viewed as part of the conduct-risk framework, not merely as commercial growth channels.
Clients are not assets to be owned. They are market participants whose decisions are shaped by institutions, platforms, incentives and information flows. The better question is not ‘who owns the client?’ but ‘who has the power to influence the client, and are they accountable for how that influence is used?’ In a fragmented market ecosystem, accountability must follow influence.
References
- Boissay, F., Ehlers, T., Gambacorta, L. and Shin, H. (2021). Big Techs in Finance: On the New Nexus Between Data Privacy and Competition. The Palgrave Handbook of Technological Finance. doi: 10.1007/978-3-030-65117-6_31.
- Doerr, S., Gambacorta, L., Guiso, L. and Sanchez del Villar, M. (2023) Big techs in finance. Bank for International Settlements Working Paper No. 1129. Available at: BIS website.
- Financial Conduct Authority (FCA). 2024. Consumer Duty board reports: good practice and areas for improvement. Available at: FCA website.
- Financial Sector Conduct Authority (FSCA) (n.d.) Treating Customers Fairly. Available at: FSCA website.
- Gerritsen, D. and De Regt, A. (2025). Influencers and Consumer Financial Decision‐Making. International Journal of Consumer Studies. doi: 10.1111/ijcs.70037.
- Roy, S. (2022). Preventing Mis-Selling and Protecting Customers in Financial Institutions. SSRN Electronic Journal. doi: 10.2139/ssrn.4142325.
