CCI Through a COO Lens: Where Disclosure Reform Hits Operations

Why CCI Feels Different from the Inside 

CCI is often described as a disclosure reform. From inside an asset manager or bank, it feels different. Not because the rules are unfamiliar, but because they place sustained pressure on operating models that were designed for periodic review rather than continuous alignment. 

Regulatory change rarely fails because firms misunderstand the regulation. It fails when new expectations collide with data structures, governance processes, and ownership models that have evolved organically over time. CCI is one of those moments. It does not introduce entirely new complexity, but it removes the tolerance for ambiguity that many firms have quietly lived with. 

What makes CCI feel different operationally is the combination of machine-readable data, distributor reuse, and ongoing material-change expectations. Together, these expose questions that were easy to defer under document-based regimes: where product data truly originates, how changes are identified and assessed, and who remains accountable once information is consumed downstream. 

What follows is not a regulatory interpretation of CCI, but a view of the operational risks it is likely to surface inside asset managers, fund managers, and banks as the framework moves from implementation into business-as-usual. 

A Test of Operational Control, Not Disclosure Design 

Much of the market conversation revolves around formats, templates, and regulatory timelines. CCI, however, is quietly probing something else: how well firms truly understand their own data, how change is governed, and how control is maintained once information leaves the organisation. 

The difficulty rarely appears at the point of publication. It appears when data changes between review cycles.  

The firms that encounter the greatest difficulty will not be those that misunderstand the regulation. They will be those whose operating models were already fragile, but where that fragility had not yet been fully exposed. 

The Golden Source Assumption 

What begins as a question of disclosure quickly becomes a question of data control. 

The real areas of concern leaders should focus on begin with a deceptively simple assumption: that the firm knows where its official product data lives. 

Most organisations believe they have a golden source. In practice, many operate with several competing versions, each considered authoritative depending on context. The same cost or risk figure may reconcile within individual systems yet differ slightly once pulled together for disclosure. Manual adjustments are layered on top of system outputs. Spreadsheet bridges quietly connect platforms that were never designed to speak to one another. 

Reconciliation often happens silently, performed by individuals who know how to make things align but whose knowledge is rarely documented or scalable. 

CCI exposes this reality because firms are now required to provide machine-readable data alongside disclosures. That data must be demonstrably consistent with what investors see, and traceable back to governed sources. 

This becomes a simple but unforgiving operational test: can the organisation confidently trace any disclosed data point — whether cost, risk, or performance — back to a governed source and clearly explain how it was derived? 

When Document Sign-Off Stops Being Control 

A closely related concern is the long-held assumption that document sign-off equates to control. 

Historically, governance ended once a disclosure had been reviewed and approved. Under CCI, that model no longer holds. Approving a document does not guarantee ongoing control if the underlying data continues to move. 

When data shifts, someone must notice. Someone must decide whether the change is material. Someone must trigger updates across documents, datasets, and distributors. 

Approval workflows that govern PDFs but not the data behind them leave a widening gap between perceived and actual control. 

Material Change and Continuous Oversight 

That gap becomes more pronounced when material change enters the picture. 

CCI requires disclosures to be updated following a material change yet offers limited prescription on thresholds. At the same time, risk indicators move to a more granular scale, with narrower volatility bands that increase the likelihood of movement. 

Regulators expect vigilance. Many firms, however, still rely on periodic checks tied to calendar cycles. 

This creates a structural mismatch. Leaders should be asking whether their organisation is genuinely capable of continuous monitoring, or whether it remains dependent on review models designed for a different regulatory era. 

The FCA expectation is not perfect prediction, but a clearly defined, consistently applied approach to identifying and responding to change. 

Risk Reclassification as an Operational Stress Test 

Risk reclassification itself becomes an operational stress point. 

More granular scoring may be analytically sound. Operationally, it introduces more frequent change, greater downstream impact, and increased scrutiny from distributors and platforms. 

In practice, funds sitting close to risk-band boundaries may move repeatedly over short periods, increasing both operational workload and distributor attention. Each shift can trigger disclosure updates, notifications, and investor questions. 

The critical issue for COOs is not whether risk will move, but whether those movements can be managed calmly and systematically. If every reclassification becomes a fire drill, the operating model will struggle to absorb routine volatility. 

Distributors Inside the Disclosure Perimeter 

Another area demanding sustained attention is the expanding role of distributors. 

While responsibility formally remains with the manufacturer, resolving post-distribution discrepancies can be operationally complex and time-consuming. Under CCI, distributors can adapt and supplement product summaries while relying on manufacturer-supplied data. This effectively extends the disclosure perimeter beyond the organisation’s direct control. 

New exposure emerges through version drift, inconsistent messaging, and disputes over what changed and when. 

Leaders should be focused on how alignment, control, and auditability are maintained once product data leaves the organisation and is reinterpreted downstream. 

Flexibility Without Coordination 

Flexibility is often cited as a benefit of the new framework, given the absence of a prescribed format. However, flexibility without coordination introduces operational drag. 

Distributors faced with multiple interpretations may push back, delay ingestion, or impose their own standards, increasing servicing cost and friction. Multiple interpretations of acceptable disclosure reduce comparability, increase servicing costs, and create resistance among distributors managing large product volumes. 

The question for leadership is whether flexibility becomes a strategic advantage or an unmanaged burden that slows change and increases friction. 

Cost Disclosure Brings Old Weaknesses to the Surface 

Cost disclosure brings another long-standing issue into sharper focus. 

These weaknesses often sit around third-party cost feeds, manual adjustments, and methodology changes that reconcile at document level but not across datasets. 

CCI does not create these problems. It makes them visible. 

Leaders should be asking whether they can clearly defend how costs are calculated, aggregated, and maintained across products and over time. 

Erosion, Not Explosion 

For most firms, compliance failure under CCI will not arrive as a dramatic breach or enforcement event. It will appear gradually. 

Inconsistencies will multiply. Updates will take longer. Distributor friction will increase. Trust will erode quietly. Operational cost will rise without a clear trigger. 

This is the reality of erosion rather than explosion, and it is far harder to diagnose once embedded. 

Activity Is Not Readiness 

The final and most significant risk for leadership is mistaking activity for readiness. 

Many organisations will be busy designing templates, running workshops, and producing sample disclosures. Activity creates momentum, but it does not guarantee resilience. 

The critical question is whether these efforts address root causes, or simply mask them until the next framework arrives. 

Where Leadership Attention Needs to Stay 

For COOs, the most important questions raised by CCI extend well beyond disclosure templates or implementation timelines. 

They centre on whether the organisation genuinely controls its product data, whether change can be detected early and assessed consistently, and whether decisions can be explained clearly to regulators, distributors, and investors when challenged. 

CCI does not demand perfection. It demands evidence of control, clarity of ownership, and continuity of process over time. Firms that struggle will not necessarily be those that move slowly, but those whose operating models rely on manual intervention, undocumented knowledge, or periodic review cycles that are no longer sufficient. 

Across the industry, the organisations navigating CCI most confidently are not those focused solely on redesigning disclosures, but those investing time in understanding how product data moves, where decisions are made, and how accountability is maintained once information leaves the firm. 

At FundSense, our role is to support that work by helping firms establish clear data lineage, maintain alignment between disclosed documents and machine-readable outputs, and manage change in a controlled, auditable way as product data is reused by distributors. 

The objective is not to replace judgement or operating discipline, but to strengthen the infrastructure that allows both to operate effectively under continuous regulatory scrutiny.