The Financial Conduct Authority (FCA) released Consultation Papers and Policy Statements to strengthen the Appointed Representative (AR) Regime. This followed identifying significant evidence of harm to consumers from Principals not undertaking adequate due diligence before appointing an AR and from poor ongoing controls and oversight once they were appointed. From their analysis they established that on average Principals and their AR’s generate 50 to 400% more complaints and supervisory cases than Non-Principal firms do across all sectors. As such, the FCA decided regulatory intervention was required and monitoring and reporting on AR’s were increased from the 8th December 2022.
- Appointed Representative Regime Guidance Document
- Appointed Representative Annual Review Template
- Principal Self-Assessment Document
We are extremely pleased with our AR Guidance Document, which provides a complete guide on the rules in a nice simple document. The document has been designed to be a go to guide listing exactly what firms need to do and by when. It also provides guidance on how to achieve the requirements set by the FCA in an easy-to-understand guide.
In addition to the Guidance Document, we have produced an AR Annual Review and Principal Self-Assessment Document to give firms a template which can be used to evidence that the firm has implemented the AR regime into its practices. Both documents contain a summary of the requirements that need to be met, along with a list of questions to evidence they have achieved.
All firms that have AR’s will need to complete an AR Annual Review on each of its Appointed Representative (excluding IAR’s). Principal firms will also need to complete a Principle Self-Assessment. The self-assessment is completed on the Principal firm and covers both its AR’s and IAR’s. Firms previously had 12 months from the 8th December 2022, to complete these reviews and are required to complete them at least annually, thereafter.
Firms should note, that whilst Introducer Appointed Representatives (IARs) fall under the AR Regime, the monitoring and reporting requirements are reduced due to being considered a lower risk. However, where the rules apply to IARs we have highlighted this within our guidance.